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CBA Comment to FFIEC on Social Media
Dear Ms. Dupre:
The Consumer Bankers Association (CBA)1 appreciates the opportunity to submit comments in response to the Federal Financial Institutions Examination Council’s (FFIEC’s), proposed guidance titled “Social Media: Consumer Compliance Risk Management Guidance” (Guidance). Once finalized, financial institutions and others will be expected to use the Guidance in their efforts to ensure their policies and procedures provide oversight and controls commensurate with the risks posed by social media activities.
Summary of CBA’s Comments
- We request the FFIEC agencies reconsider this approach of providing a brief summary of a non-inclusive list of laws and rules that may be relevant in social media and how they may apply. Instead, the Guidance should merely state that statutes and rules can apply in social media and financial institutions and others should incorporate these considerations in their compliance programs. Any substantive changes that may arise as a result of social media should be made to those specific laws and rules through the notice and comment process.
- The definition of “social media” is unclear and overbroad. We request the FFIEC agencies clarify that this definition of social media does not include emails or internal social media.
- We do not believe there should be a requirement or expectation of a separate risk management program for social media. Financial institutions should be permitted to integrate these components and concepts into their current risk management structure.
To read the full Comment Letter, download the PDF.