On Reviewing the Social Media Guidance Kit

Note:  infotex plans to release a response kit for the 12/11/2013 FFIEC Guidance entitled “Social Media:  Consumer Compliance Risk Management Guidance.”   

. . . . . a Dan’s New Leaf post . . . . .

As I continue to swim neck-deep in the language and meanings and implications of the FFIEC Social Media Guidance, one thing seems to be clear:  We need NOT drop what we’re doing.  We will be able to ease into this one.  Why?

We’re already in compliance with the guidance, simply because WE ARE NOT DOING ANYTHING!


Do you remember when most of us totally missed the point about social media?  Back in 2006, when confronted with the Facebook concept (and the notion we’d need to develop an entire new policy angle based on an entirely new asset type), we said:  Just don’t use it.  It’s a passing fad.  We looked at the decline of myspace and . . . . perhaps it was wishful thinking . . . returned to our risk assessments and the debates we were having with our on-line banking providers over the meaning of the term: two-factor.

We solved the social media problem by banning the use of social media from within our networks and by our organizations until about 2009, when it occurred to us that banning its use on bank assets did nothing to mitigate the risk from employee-owned and other third party social media sites.  That was when we realized that we needed a new framework.

And we built that framework.  For most, it was a training centered around a social media policy that many just inserted directly into their Acceptable Use Policy.

Meanwhile, enter the notion of malware and fraudulent applications and other attack vectors.  And the fact that crime organizations see social media as an effective vehicle to the target was solved by adding warnings into the training framework.  And now that we’ve convinced the collective that connecting to the internet opens a door to the entire world, we simply needed to help them understand that setting up a social media account was like opening a giant garage door!


But back to the kit . . . eventually market forces will force us to abandon our position that the best way to protect ourselves against COMPLIANCE RISK is to simply do nothing.  The training framework has successfully forbid loan applications or advertising new products and services . . . . partially out of fear that we would fail to provide a disclosure or disclaimer; and in deference to the notion that we could be turning millennials off.


While I’m not sure if it is good or bad news, the guidance serves as a map to help us exploit new opportunities as they arise . . . in the areas of lending, advertising, and/or payment systems.

But let us laggards remember that the rest of the world . . . .the non-regulated world . . . is learning how to put  a great big e in front of social media.  And let’s remember that the guidance acts as if payment systems WILL be the future of social media, whether we think it’s safe or not.

Yes, we do not need to jump head-first into compliance with this guidance, like we had to with the June 2011 Supplement to the Authentication Guidance.  And why?

Think about it.  Think about the notion that auditors/examiners find the problems, but never offer solutions.  Remember?  Think about how bankers usually have to blaze the trail in fixing security issues; in almost like a trial/error fashion, until our examiners say “yes, that is what I was looking for.”

The biggest complaint I always hear about the supervisory process is that examiners usually know the problem exists, but rarely know how to fix it until we get to the late majority phase of adopting the appropriate solution.  This is not the case with social media.

In the case of legal/compliance risk on social media, this guidance turns that notion upside down.  The FFIEC is blazing the trail, seemingly daring us to take more risk on social media assets.

It’s like the FFIEC realized that we weren’t going to lead on this one.

Original article by Dan Hadaway CRISC CISA CISM.
(Alias: the one who thought Facebook was a passing fad!)

Founder and Managing Partner, infotex

“Dan’s New Leaf” is a “fun blog to inspire thought in the area of IT Governance.”

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