Additional burdens that could stifle innovation and cause undue hardships to credit unions and other financial institutions, regardless of whether they even use social media, are concerns that CUNA raised in a comment letter to the Federal Financial Institutions Exam Council (FFIEC) on its proposed “Social
Media: Consumer Compliance Risk Management Guidance.”
“The Guidance should not represent a barrier to these financial institutions, but should offer a framework to make the implementation of social media programs easier for financial institutions,” CUNA wrote. “The Guidance should be a useful tool for implementing existing regulations and not an additional set of requirements impeding the use of social media by financial institutions.”
In the letter – which comments on a proposal the FFIEC made in January – CUNA outlined three major concerns with the guidance and one concern with the
use of the guidance in general.
The three major concerns with the guidance are:
- It is overbroad because it seeks to define social media with examples rather than offering a true definition that can be applied to new products and services as they appear in the marketplace;
- It creates additional duties for financial institutions;
- It offers little in ways of information that can help financial institutions comply with current laws.
Regarding overall concern with the use of the guidance, CUNA noted that it may “effectively be treated as law by regulators when they examine credit
The complete text of CUNA’s letter is here.