Mortgage Lenders` Use of Social Media

Mortgage Lenders’
Use of Social Media―
Balancing the Benefits and the Risks
A CohnReznick White Paper
JUNE 2014
Whether a company was an early adopter
of social media or is just now dipping its toes
in the water, the risks associated with an
enterprise’s presence on social media
platforms have to be carefully weighed
against the benefits.
When the Federal Financial Institutions Examination Council (“FFIEC” or the “Council”)―
composed of several major financial and governmental agencies1―released its proposed
social media guidelines for financial institutions in January 2013, lenders were concerned
about the potential implications. Many of the recommendations within the guide have since
been clarified and now lay out a comprehensive “handbook” on how financial institutions
should execute social media and networking strategies. To assist the lending community in
navigating the social media waters, CohnReznick presents the following insight on what all
types of lenders can do to mitigate the risks associated with the use of social media while
embracing its benefits.
What Is Social Media … and What Is It Not?
In its notice titled, “Social Media: Consumer Compliance Risk Management Guidance,”2 the
FFIEC describes social media as a hyper-interactive, dynamic and constantly evolving form
of communication. Examples of social media platforms provided within FFIEC’s guidance
include platforms that enable:
• Micro-blogging (Facebook, Google+, MySpace, Twitter)
• Organization of forums, blogs, customer reviews/testimonials, and online bulletin boards
(Blogger, WordPress, Yelp)
• Sharing of photos and videos (Flickr, YouTube, Instagram, Pinterest)
• Social gamification and virtualization (Badgeville, FarmVille, CityVille, Second Life)
However, the FFIEC’s guidance only hints at how broad the overall scope of social media is.
The rapid growth of all things “social” has proven to be overwhelmingly difficult to keep up
with and has rendered even the most recent and relevant publications slightly inaccurate
with regard to the exact number of current platforms and their diverse capabilities. Although
we may never be able to pin these numbers down precisely, Figure 1 on page 2 does an
admirable job at demonstrating the far-reaching breadth of social media platforms as well
as their competencies.
For the purposes of this whitepaper, we will not be touching upon email and text messaging
as they are not to be included under the social media “umbrella” per the Council’s guidance.
A financial institution’s or lender’s website would not be considered a part of its social media
mix either, unless the site includes capabilities similar to those noted above.
1
The agencies composing the FFIEC include, but are not limited to, the Consumer Financial Protection Bureau (CFPB),
the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA).
2
FFIEC. (2013) Social Media: Consumer Compliance Risk Management Guidance. Retrieved from
http://www.ffiec.gov/press/pr012213.htm
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Figure 1: The Conversation Prism3
If You Snooze, You Lose
As the world embraces social media as a way to connect with one another, non-participation
in the medium is no longer an option. Customers seeking a service provider will do so online,
and a stale Facebook page or stagnant Twitter feed gives a negative impression of the business.
Customers naturally gravitate to companies who show an eagerness and seriousness in
wanting to do business with them. In addition to reinforcing brand recognition, participation
in social media has a host of other benefits, including repeat exposure to who you are and
what you do, the opportunity to influence and engage your community by sharing information
and establishing yourself as a credible knowledge leader, and the ability to gain a competitive
advantage over competitors who may fall short in their own social media programs.
Organizations are also using social media to keep tabs on the market, their industry,
customers, etc., and make adjustments to their strategies as required.
3
Brian Jolis and JESS3. (2013) The Conversation Prism. Retrieved from http://conversationprism.com/
2 | Mortgage Lenders Use of Social Media
According to a 2013 report4 conducted by the Center for Marketing
Research at the University of Massachusetts Dartmouth of the 500
fastest-growing private companies in the U.S. as compiled annually
by Inc. Magazine, 77% of companies maintain active Twitter
accounts, 70% have Facebook pages, 69% have YouTube accounts,
and 34 percent are actively blogging. The use of LinkedIn grew to 88%
in 2013, making it the platform of choice for the Inc. 500.
In addition, there is a correlation between a company’s social media
engagement and its financial performance. According to a survey5
conducted in November 2013 by LinkedIn and TNS of 998 North American
small- and medium-sized businesses (SMBs) with revenue between
$1 million and less than $50 million, 81% said they use social media,
and of this group, nearly all of them (94%) use it to market their
businesses. Seventy-three percent of hyper growth SMBs (those
experiencing significant increases in revenue) reported an increased
spend on social media. Additionally, they are finding social media to
be a highly effective way to maintain brand presence and identity
(90%) and a meaningful source of lead generation (82%).
While the majority
of businesses
acknowledge the
benefits of social
media, few have
developed a
comprehensive
strategy to harness
and control it.
Whether a company was an early adopter of social media or is just now dipping its toes in
the water, the risks associated with an enterprise’s presence on social platforms have to be
carefully weighed against the benefits. It is quite common for a company’s social media
efforts to be spearheaded by marketing or other business teams, such as sales, with little or
no input from the information technology (“IT”) and compliance departments. This makes
their jobs that much more difficult, as they are forced to play catch up with regard to
their strategies to mitigate the risks associated with the new social media exposure points.
Oftentimes, we find that existent legal and human resources functions within organizations
were not properly consulted and brought into the social media governance fold. This is not
only a waste of valuable resources, but is also a surefire way to leave one’s organization
susceptible to episodic non-compliance.
While the majority of businesses acknowledge the benefits of social media, few have
developed a comprehensive strategy to harness and control it. Impediments include fear
of its misuse, security vulnerabilities, or compliance issues. Most social media strategies focus
more on the tools and tactics than on its ability to have a positive impact on the bottom line.
In Auditing Social Media – A Governance and Risk Guide,6 the authors state, “to build the
business case for social media, only a comprehensive strategy aligned to business objectives
combined with policies and procedures that mitigate risk will be able to properly demonstrate
value while calming fears.” A real strategic plan, adds the authors, “recognizes that the purpose
of social media is to develop relationships and use the appropriate social technologies to
leverage connections and conversations between real people, and it involves a new level
of commitment to learning and collaboration. A true social media strategy has the greatest
ability to support the achievement of business objectives.”
4
Nora Ganim Barnes, Ph. D, Ava M. Lescault, MBA. (2013) LinkedIn Rules But Sales Potential May Lie with Twitter.
Retrieved from http://www.umassd.edu/cmr/socialmediaresearch/2013inc500/
5
LinkedIn, TNS. (2013) Priming the Economic Engine: How Social Media is Driving Growth for Small and Medium Business (SMBs).
Retrieved from http://marketing.linkedin.com/blog/social-media-a-hotbed-for-smb-growth-and-fertile-ground-for-financialservices-prospects/)
6
Peter R. Scott, J. Mike Jacka. (2011) Auditing Social Media – A Governance and Risk Guide
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For mortgage lenders, a social media strategy will seek to engage future customers in a
meaningful manner while at the same time align business goals with compliance implications.
Companies can learn from the mistakes of those entities that got burned after blindly jumping
into social media use without first and foremost having considered the variety of risks posed
by these platforms. Only once a comprehensive assessment of the nature of these risks has
been performed can the development of mitigation plans begin.
Social Media’s Inherent Risks
According to the FFIEC, there are three types of risk associated with a financial institution’s
use of social media:
• Compliance and legal risk
• Operational risk
• Reputational risk
The mismanagement of these risks can place a lender’s vital assets within the near grasp
of danger―including their stored data (including confidential customer data), the integrity of
their operational infrastructure, their brand’s reputation, favorable compliance standings and,
in some cases, even their bottom lines.
Social Media and Legal Compliance
There has been some confusion as to whether the FFIEC’s guidance should be regarded as a
set of regulations or simply used as a “guiding hand” through which financial institutions and
lenders develop their own risk management plans. Elizabeth Khalil, senior policy analyst with
the FDIC and one of the authors of the FFIEC’s guidance, stated that the document does
not create any new obligations in and of itself by which financial institutions must abide.
However, financial institutions can, in fact, violate laws and regulations denoted within the
guidance. Several of the laws mentioned apply directly to mortgage lending and, without
proper social media risk monitoring and management, can serve as grounds for regulatory
non-compliance.
For example, to be in compliance with Fair Lending Laws and the Equal Credit Opportunity
Act (ECOA), all communication must not solicit, collect, or discriminate based on information
related to a consumer’s race, color, religion, national origin, or sex. However, since many
social media platforms already collect and present this information, lenders should insulate
themselves from Fair Lending Law and ECOA non-compliance accordingly. This can be
accomplished by establishing and documenting compliance training programs for their
loan officers through which they are made aware of the potential consequences of
inappropriate and unsanctioned practices including, but not limited to, the misuse of
consumer information.
4 | Mortgage Lenders Use of Social Media
Another example that illustrates the relation between social media and compliance is the
Real Estate Settlement Procedures Act (RESPA). Section 8(a) of RESPA prohibits the acceptance of
fees, kickbacks, or “things of value” for the referral of settlement business. Section 8(b) prohibits
the acceptance of portions, splits, or percentages of charges for real estate settlement services.
These prohibitions apply to all applications taken electronically, including those taken via social
media. An example of a RESPA violation would be a referral-based “contest” or “raffle”
hosted online or on a social network where a loan officer’s clients send him/her referrals in
exchange for an opportunity to win “things of value” or “kickbacks.” Employees of lending
institutions may be tempted to engage in these activities to boost leads, not realizing the
potential legal risk at which they are placing themselves and their employers.
These are just a few of many possible examples illustrating how improper use of social media
by a lender can reflect on its legal compliance status.
Social Media and Operational Risk
Because social media use is relatively new ground for lenders, some may decide to freely
introduce these technologies as enterprise-wide business development and marketing tools
without first having well-developed IT risk assessments and incident response plans in place―
ultimately leaving themselves susceptible to operational risk.
Operational risk is defined by the Council as a risk of loss resulting from inadequate or
failed processes, people, or systems. Operational risk strongly ties into social media from
an IT perspective and requires proper oversight and management of an institution’s IT
infrastructure. Social media is one of many channels susceptible to account hijackings
and malware intrusions and, as such, lenders should ensure that the controls it implements
to protect its infrastructure and consumer data from malicious breaches appropriately
address social media channels as well. Companies should also ensure that their revised
incident response plans and protocols regarding cyber security breaches account for
social media.
Social Media and Reputational Risk
The Council defines reputational risk as risk arising from negative public opinion. Activities
that ultimately result in discontented consumers and/or negative publicity can severely
harm any company, even one with contemporaneously robust operational infrastructure
and compliant legal standing. Reputational risk is the most diverse of the risks associated
with the organizational use of social media and comes in several forms:
• Fraud and Brand Identity
― Outsiders can create a social media profile fraudulently representing your business
and broadly distribute false company-related information as well as intake misled
customers’ credentials.
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• Privacy Concerns
― Lenders should consider the potentially adverse reactions of the public to any use
of protected or unprotected personal information through social media.
• Third-Party Concerns
― Working with third-party social media service providers can expose mortgage lenders
to substantial reputational risk – especially because end users of third-party sites are
more than likely to blame the lender for any problems or complications that may occur
on the site, such as the misusage of personal information or vague policy modifications.
• Mismanagement of Consumer Complaints and Inquiries
― Another opportunity for reputational risk arises when lenders and financial institutions
do not monitor and address consumer complaints and inquiries in a timely, appropriate
manner as these are capable of going viral at any time.
• Independent Employee Use of Social Media Platforms
― Mortgage lenders should be aware that employees’ independent communications on
social media platforms can be viewed by the public as reflecting their official policies
and views.
― The risk can be further elevated by “rogue” loan officers if these employees decide to
distribute or collect information in a manner that is unsanctioned by their employer’s
practices and policies. However, thorough documentation and employee sign-off
processes proving an employer’s provision of training related to company-sanctioned
social media practices can prove helpful towards the mitigation of these risks. In addition,
lenders should monitor the quality, integrity, and accuracy of all data and claims distributed
by their officers through these channels to ensure proper mitigation of reputational risk.
The Fourth Risk―Opportunity
In addition to the risks identified by the FFIEC, CohnReznick offers opportunity risk as a fourth
category. The perils generally associated with enterprise usage of social media can easily
overshadow the incredible value that social networks can have to mortgage lenders and
loan officers.
Social media has provided us with a humanizing channel through which we can establish
relationships with new clients while keeping tabs on ongoing client relations. Social networks
may also hold the Rosetta Stone to future communication with millenials―the generation
emerging from the Digital Age―who have recently been seeing ever-increasing purchasing
power and are soon to be fully immersed in the housing market. This generation was born
at the dawn of widespread technology usage and has come of age speaking in bits and
bytes. The adoption of social media by mortgage lenders and other financial institutions can
help decipher this language and facilitate communication and engagement with this vital
market segment as we have learned from the recent successes of the entertainment and
retail industries.
6 | Mortgage Lenders Use of Social Media
These four risks combine to create a “perfect storm” of sorts―affording
lenders and financial institutions with an opportunity to develop a
comprehensive, customized risk management program with integrated
efforts from functions across the entire organization. This program, when
designed and executed effectively, can help lenders implement the
policies, controls, and processes necessary to properly monitor, mitigate,
and control the severity of these risks’ effect on their assets.
Social Media Risk Management in the Context
of Mortgage Lending
One of the most significant driving points behind the FFIEC’s guidelines
is that all types of consumer lenders should have a risk management
program that enables them to identify, measure, monitor, and control
the risks related to social media. These best practices should be
developed as a conjunctive effort with inputs from the company’s
operational staff including, but not limited to, specialists in compliance
and legal, information technology and security, human resources,
and marketing.
When designed and
executed effectively,
a Social Media Risk
Management
Program can help
lenders implement
the policies, controls,
and processes
necessary to properly
monitor, mitigate, and
control the severity of
these risks’ effect on
their assets
In conducting social media audits for organizations across several industries, CohnReznick
has found a common thread of unaddressed control and process gaps―demonstrating that
many enterprises jumped onto the social media bandwagon without first having developed
a comprehensive, all-encompassing risk management program with the proper controls
and processes in place prior to the introduction of organizational social media use. We
also discovered a strong correlation between the components of the FFIEC’s proposed risk
management program and the recommended controls that eventually remediated the
gaps found amongst our social media internal audit clients. With that said, in the table on
pages 8-9 we have listed the components of the Council’s social media risk management
program along with our interpretations and the risks associated with their neglect.
cohnreznick.com | 7
FFIEC's
Recommended
Controls
CohnReznick's Interpretation
Risks Associated with Not Establishing
These Controls
Governance structure
by which senior-level
management directs how
social media usage can
contribute to strategic
goals and initiatives and
establishes controls and
ongoing assessments
of risk related to social
media activities.
Before delving into its use, the board of
directors and/or senior-level management
should discuss how social media fits
into the company's current strategy as
well as which controls will be instituted
and how they will be managed and
monitored.
• Lack of top-down awareness and
knowledge of social media use
Developed policies and
procedures regarding
the usage and monitoring
of social media and
compliance with applicable
customer protection laws
and regulations.
Social media may generally be
considered a realm where a company
can "let go" of its corporate inhibitions.
However, financial institutions should
establish content approval processes
to assist in shielding themselves from
non-compliance with customer protection
laws and regulations.
• Legal risks including, but not limited to,
costly lawsuits, regulatory penalties, and
other ramifications of non-compliance with
applicable laws and regulations such as
Fair Lending Laws, RESPA, and Section 5 of
the Federal Trade Commission's Act, which
prohibits unfair, deceptive, or abusive acts
and practices
Due diligence processes for
third-party relationships in
connection with social media.
Financial institutions should conduct
thorough due diligence on potential
third-party social media service
providers as they will be providing
consumers with a company's primary
online touch points.
• Misrepresentation of company through
third-party's practices
Contractual language should be
included in formal agreements with
third parties addressing their social
media responsibilities.
Documented employee
training program
incorporating policies
and procedures for
use of social media.
Oversight process for
monitoring information
posted by financial
institution or contracted
third parties.
• Misaligment with corporate strategies
• Lack of accountability for risk oversight
• Operational risks including, but not limited
to, account hijackings or theft of consumer
information stemming from a third party's
potentially weak operational and information
technology infrastructure
Social media training should be
conducted to ensure that employees
understand the purpose of the
organizational use of these platforms
and their respective roles within
these initiatives.
• Introduction of legal, compliance, and
operational risks stemming from employee
misuse of social platforms
All proprietary social media channels
should be closely monitored to ensure
that all content posted by the company,
its consumers, and/or third-party vendors
is in compliance with both internal policies
and applicable laws and regulations.
• Reputational risk associated with fraud and
misrepresentation of brand
8 | Mortgage Lenders Use of Social Media
• Lack of organizational insulator in the case
of a "rogue" employee's unethical actions
• Independent employee use of social media
platforms reflecting on company's official
policies and beliefs
• Inappropriate, untimely management of
consumer complaints and inquiries
• Compliance and legal risks including, but
not limited to, non-compliance with Truth in
Lending Act and Section 5 of the Federal
Trade Commission's Act
FFIEC's
Recommended
Controls (cont'd.)
Audit and compliance
functions to ensure
ongoing compliance with
internal policies as well
as applicable laws and
regulations.
CohnReznick's Interpretation
Risks Associated with Not Establishing
These Controls (cont'd.)
The majority of financial institutions
already have some form of audit
and compliance functions in place.
That being said, these departments
can be leveraged for the purposes of
company-wide social media initiatives
by being brought into the mix and
further assisting the company in
lessening vulnerabilities related to
non-compliance with applicable
laws and regulations.
• Legal and compliance risks including, but
not limited to, non-compliance with Fair
Lending Laws, the Equal Credit Opportunity
Act, and RESPA
(cont'd.)
• Stale controls rendered inadequate by the
constantly evolving regulatory environment
Assurance processes should be
conducted periodically to ensure that
the company's social media usage
continues to comply with applicable
laws and regulations.
Parameters for providing
reporting enabling
evaluation of social media
program's effectiveness
and whether it is achieving
its stated objectives.
While it is difficult to measure or quantify
social media ROI, there are tools to
help gauge these metrics including, but
not limited to, levels of engagement
with customers, overall social media
sentiments, and how the company
is performing on social media as
compared to competitors.
• Failure to set parameters for the evaluation
of a company’s social media program
makes it difficult to gauge its effectiveness
and calls into question its purpose
• If there is no accountability for sustaining
the platforms and adding new content on
a regular basis, the company is exposed to
reputational risk as sites languish
• If social media is not integrated into the
organization’s overall goals and objectives,
resources invested in its planning, implementation,
and oversight have gone to waste
cohnreznick.com | 9
The Council explains that the size and complexity of the risk management program should
be proportionate to the breadth of the company’s involvement on these platforms. However,
regardless of the size of a mortgage lender’s operation, a set risk management program
should be in place in order to monitor and mitigate the risk associated with the use of these
communication platforms.
From a technology perspective, there are several, widely available social media monitoring
tools and platforms for even the smallest of mortgage lenders such as HootSuite and TweetDeck
which, for a relatively small monthly fee, empower their users with the ability to monitor
their social platforms. More powerful data discovery applications such as QlikView offer an
integrated view across various social media channels that enable users to attribute online
conversations to specific parts of their business, allowing accelerated responses to sentiment
regarding brand, campaigns, and their associated effectiveness. Dashboard functionality
enables users to quickly compare their social media activity against their competitors’,
monitor sentiment (both positive and negative), and make informed adjustments to their
business strategy based on measureable trends, not hunches.
Figure 2: Portion of QlikView's Social Media Risk Monitoring Dashboard7
NUMBER OF HIGH RISK INCIDENTS—
Number of Tweets and Facebook Posts Over Time
Company A
80
Company B
60
Company C
40
Company D
20
Company E
My Company
7
13
0-
08
20
13
-1
0-1
13
20
20
13
-1
0-
9-0
13
20
13
20
03
28
23
9-0
-0
13
20
20
13
-0
9-
9-
13
18
0
Qlikview Social Media Risk Monitoring Dashboard. Example from Qlik (www.qlik.com).
10 | Mortgage Lenders Use of Social Media
Figure 3: Social Media Sentiment Analysis Illustrated Using QlikView8
What Is Sentiment Analysis?
Combined Sentiment Scores for
Twitter and Facebook
Sentiment Analysis is the processing of
words to identify subjective information.
Humans do this all the time: we scan
a sentence to understand the attitude
of the speaker/writer. We look to
understand if the author has a positive,
neutral, or negative tone.
0.6
Twitter
Facebook
0.4
Computer sentiment analysis tools look
to do the same thing. A program will
scan text to decifer the sentiment of
the author. The longer the text sample,
the better chance the computer has to
understand the sentiment. Text can then
be scored with a value, based on the
perceived tone.
0.2
E
M
y
C
C
om
pa
ny
D
pa
om
pa
ny
om
om
C
pa
pa
C
C
ny
C
B
ny
A
ny
om
pa
om
C
ny
0.0
There are many sentiment analysis
tools in the market today, but this
application uses Repustate, Twitter
Sentiment, and Random.
Twitter and Facebook Average Sentiment Over Time
20
Company A
15
Company B
10
Company C
5
Company D
0
Company E
My Company
-1
13
20
-0
13
20
-0
13
20
0-
01
9-
01
8-
01
-0
13
20
-0
13
20
-0
13
20
7-
01
6-
01
5-
01
-0
13
20
-0
13
20
-0
13
20
4-
01
3-
01
2-
01
1-0
13
20
01
-5
Once these controls have been fully implemented, lenders should take part in assurance
reviews―the periodic and ongoing monitoring of risk programs and the updating of controls
that have lost their relevancy. In its 2010 white paper Social Media: Business Benefits and
Security, Governance and Assurance Perspectives9, ISACA (formerly Information Systems
Audit and Control Association) says “it is the role of the assurance professionals within
the enterprise to validate and monitor these controls to ensure that they are, and remain,
effective and that compliance with these controls is established and measureable.”
8
Social Media Sentiment Analysis Illustrated Using QlikView. Example from Qlik (www.qlik.com).
ISACA. (2010) Social Media: Business Benefits and Security, Governance and Assurance Perspectives.
Retrieved from http://www.isaca.org/Knowledge-Center/Research/ResearchDeliverables/Pages/
9
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The elements identified in ISACA’s Business Model for Information Security can be used by
assurance professionals to ensure that risks are being appropriately managed:
Strategy and
Governance
• Has a risk assessment been conducted to map the risks to the
enterprise presented by the use of social media?
• Is there an established policy (and supporting standards) that
addresses social media use?
• Do the policies address all aspects of social media use in the
workplace―both business and personal?
People
Processes
Technology
• Has effective training been conducted for all users, and do users
(and customers) receive regular awareness communications
regarding policies and risks?
• Have business processes that utilize social media been
reviewed to ensure that they are aligned with policies and
standards of the enterprise?
• Does IT have a strategy and the supporting capabilities to
manage technical risks presented by social media?
• Do technical controls and processes adequately support social
media policies and standards?
• Does the enterprise have an established process to address the
risk of unauthorized / fraudulent use of its brand on social media
sites or other disparaging posting that could have a negative
impact on the enterprise?
The Bottom Line
Social media plays a significant role in communication and marketing across many
industries and that role is likely to become more significant in the future. The migration
from “old world” ways of conducting business to today’s real-time, transparent methods
may appear understandably daunting to lenders – especially when their own policies
as well as relevant laws and regulations have not been able to fully keep pace with the
dynamic changes of the social media marketplace.
Mortgage lenders should not discourage their loan officers from using social media as
a means of client acquisition and communication as their participation within this arena
may result in larger volumes of leads, faster conversion rates, and ultimately, more business
for the organization. Lenders should, however, be sure to establish company-wide social
media best practices and risk management programs, including training and monitoring
platforms, in order to remain in compliance with internal policies as well as all applicable
laws and regulations.
12 | Mortgage Lenders Use of Social Media
Key Takeaways
• For the purposes of this white paper, social media is defined
as a hyper-interactive, dynamic, and constantly evolving form
of communication.
• As per the FFIEC’s guidance, financial and lending institutions
should have all-encompassing, fully-integrated and scalable risk
management programs enabling them to identify, measure, monitor,
and mitigate the risks associated with organizational usage of social
media―including operational, legal, and reputational risks.
• Though the FFIEC’s guidance is not considered a regulatory
document in and of itself, adherence to its prescribed risk
management program components can assist financial and
lending institutions in remaining compliant with laws and regulations.
• Social media-based communication will play a significant role in
financial dealings going forward and a failure to adapt and integrate
it throughout an organization’s initiatives can result in another
significant risk―opportunity risk.
By establishing proper
social media-related
controls, policies,
procedures, training
programs, and audit
functions, financial
and lending institutions
can make strides
toward insulating
themselves from
non-compliance
while enjoying the
many advantages of
organizational social
media usage.
• By establishing proper social media-related controls, policies, procedures, training
programs, and audit functions, financial and lending institutions can make strides
toward insulating themselves from non-compliance while enjoying the many advantages
of organizational social media usage.
For more information, please contact George Gallinger, Principal and National Director of
CohnReznick Advisory Group’s Governance, Risk, and Compliance Practice at 973-871-4060
or [email protected], or Roberta Janel, CMB, Director at CohnReznick
Advisory Group at 973-871-4027 or [email protected].
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matters.
CohnReznick LLP © 2014
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