Successful Social Media for Mortgage Lenders: Engage With Your Audience While Maintaining Compliance Obligations
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The document outlines the importance of social media for mortgage lenders, detailing the various platforms and compliance requirements necessary to engage effectively with customers. It emphasizes the need for a risk management program to address potential consumer compliance issues, along with best practices for policy creation, monitoring, and training of employees. Additionally, it suggests the establishment of governance structures and oversight processes to ensure adherence to legal guidelines and maintain a positive reputation.
Successful Social Media for Mortgage Lenders: Engage With Your Audience While Maintaining Compliance Obligations
- 1. Successful social media for mortgage lenders: Engage with your audience while maintaining compliance obligations
- 2. What is Social Media? • Interactive online communication, in which users can generate and share content through text, images, audio, and video. • Different channels/formats: • Microblogging sites: Facebook, Twitter, Google Plus, Instagram • Customer review websites and bulletin boards: Yelp, Google Local, Citysearch • Photo and video sites: YouTube, Flickr • Forums • Blogs • Professional networking sites: LinkedIn • Virtual worlds: Second Life • Social games; Farmville
- 3. Social Media is Ubiquitous • As of January 2014, 74% of online adults use social networking sites* • Fully 40% of cell phone owners use a social networking site on their phone, and 28% do so on a typical day.* • 33% of Facebook posts are done on mobile devices according to HubSpot • Social media has a 100% higher lead to close ratio than outbound marketing *Pew Internet Project’s research related to social networking
- 4. New Guidance for Mortgage Professionals According to the Federal Financial Institutions Examination Council: “A financial institution should have a risk management program that allows it to identify, measure, monitor, and control the risks related to social media.” Social media: consumer compliance risk management guidance Federal Financial Institutions Examination Council (FFIEC) January 2014
- 5. • CFBP is clear in its guidance. Now lenders must comply. You should be able to address questions or complaints in a timely and appropriate manner.
- 6. Reputation Risk Even if you don’t maintain a corporate social media presence, you still must be vigilant: • Spoofing, phishing, “fraudsters masquerading as the institution” • Employee’s communications via social media may be viewed by the public as reflecting the financial institution’s official policies • Privacy: members posting personal, sensitive, or confidential information.
- 7. Critical Considerations Oversight and Governance • How to track and manage • How to train • When to say “NO”/Fight sales’ pushback • Establish a code of conduct • Train and re-train all employees, especially sales, servicing, marketing • Have employees self-register their online presences through internal company records
- 8. Step 1 – Create a Policy • Define your social media objectives • Set policies and procedures regarding the use and monitoring of social media • Establish an employee training program that incorporates company policies and procedures for official and unofficial use of social media • Establish content guidelines • Define a list of impermissible activities for employees • Create a written plan that provides controls and ongoing assessment of risk in social media activities
- 9. Best Practices: Policy Creation • Who’s doing the talking? • Be listening • Determine the rules • Prepare for the worst • Hold people accountable • Make it a living document
- 10. Listening Channels SET UP YOUR LISTENING CHANNEL • GOOGLE ALERTS • NEWSLE • TWILERT • LINKEDIN • MENTION • TWITTER
- 11. Step 2 – Monitoring & Governance • Design a social media risk management program with participation from various aspects of the business unit, including legal, sales, marketing, compliance, technology, information security, and human resources. • Create a governance structure with clear roles and responsibilities. • Define oversight process for monitoring information posted to the internet. • Set audit and compliance functions to ensure ongoing compliance with internal policies and all applicable laws and regulations (CFPB, State Regs.). • Establish reporting methodology for information to senior management on social media risk issues
- 12. Considerations for evaluating solutions Pre-Review vs. Post-Review Multiple Content Types Hosted vs. On-Premise Admissibility of monitored data Website monitoring Replication of data Contextual review (don’t flatten!) Automated policy review
- 13. Q&A Contact Info Dan Carroll /[email protected] www.smarsh.com facebook.com/SmarshInc @SmarshInc Linkedin.com/companies/smarsh
Editor's Notes
- #6: But as with everything else in the mortgage industry, there are rules that govern how we behave in these outlets. Innovation usually outpaces regulation, but regulation eventually catches up and holds firms accountable for activities even before the guidance was completely clear. So you must ask yourself, what policies does your firm have in place and what regulations do apply to social media? As a registered representative you need to know what the regulators are saying about electronic communications, including social media, and they are saying a lot. (same talking points from SEC slide in FiPath deck)
- #10: A social media policy documents the guidelines and rules of social media activity performed by you or your advisors as they pertain to the vision and philosophy of your business. Who is authorized to represent the firm in a social capacity? What is your plan for when your primary social media person leaves the company? Appoint someone to monitor the outbound activity of the firm and the external online chatter about the company. Detail every requirement regarding compliance and archiving around social media and clearly specify the consequences of non-compliance. Despite all the best planning, sometimes things go awry. Include a plan for the worst-case scenario and make sure your policy has every base covered. Have a system in place to distribute your firm’s social media policy, with specific actions outlined for people who need to sign and return the policy to your HR, legal, or compliance team. Advisors who use social media on behalf of your firm must acknowledge and understand that communications over networks will be archived and supervised, in accordance with compliance regulations. Regularly review your social media policy to keep up with the needs of your business, changing technology, and new regulations.
- #11: SET UP YOUR LISTENING CHANNEL To develop a listening channel, here are some mostly free tools to get you started. Create a separate email address (ex: listen@yourorg. com) to help you sort through all of the email updates you’ll receive. GOOGLE ALERTS to stay on top of news in your area, specific customers’ activities, and prospect news. Track your firm name and the names of competitors. NEWSLE is a service that helps you track when your contacts are mentioned in newsletters, articles, white papers, etc. TWILERT is a Google Alerts version geared for Twitter. LINKEDIN allows you to search the updates of everyone in your network using specific phrases or words. MENTION enables users to monitor personal and professional brands, offering a Google-like alert for most every online space. TWITTER Social profile settings provide a simple way for you to be notified when someone tweets your name or firm name. Check the settings area under mobile and email. Facebook has a similar function.
- #13: Monitoring solution should be automated – don’t rely on a manual process that allows for missing or deleted information Solution should account for multiple message or content types: websites and social media Solution should capture and render each message type in its original native format Ensure you’re capturing all content including comments, likes, uploads, etc.