Community Bankers of Iowa Monthly Banker Update January 2014 | Page 11

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4. Existing Regulations and Social Media
The FFIEC Guidance identifies over a dozen regulations that
are affected by the social media guidance, including Truth in
Savings/Lending, Fair Debt Collection Practices Act, Unfair,
Deceptive, or Abusive Acts or Practices, Deposit Insurance or
Share Insurance, Electronic Fund Transfer Act, and others. Of
note in the Guidance is that the laws and regulations discussed
in the Guidance do not contain exceptions regarding the use of
social medial. Thus to the extent that financial institutions use
social medial to engage in customer transactions, the institution
must comply with all applicable laws and regulations as if these
activities were conducted through other media.

As with other FFIEC guidance, this social media guidance is
not a “one-size-fits-all” approach; rather financial institutions
are expected to assess and manage the risks particular to
the individual institution, taking into account factors such as
the institution’s size, complexity, activities, and third party
relationships.
A copy of the press release and the Guidance can be found at
http://www.ffiec.gov/press/pr121113.htm.

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CBI Banker Update | JANUARY 2014

11