In This Issue:
- FEDERAL ISSUES
- STATE ISSUES
- FIRM NEWS
- FIRM PUBLICATIONS
- CONSUMER FINANCE
- Excerpt from E-Commerce:
Federal Regulators Propose Guidance for Social Media Use. On January 22, the FFIEC proposed guidance on the applicability of consumer protection and compliance laws, regulations, and policies to activities conducted via social media by federally supervised financial institutions, as well as nonbanks supervised by the CFPB. With regard to compliance and legal risks, the guidance addresses (i) the applicability of existing federal laws and regulations to the use of social media for marketing and originating new deposit and lending products and the use of social media to facilitate consumer use of payment systems; (ii) the need to apply BSA/AML internal controls to customers engaging in electronic banking through the use of social media, and e-banking products and services offered in the context of social media, as well as BSA/AML risks emerging through the growing use of social media; (iii) CRA monitoring of social media sites run by an institution; and (vi) customer privacy issues associated with social media. The guidance also reviews reputational risks related to social media, including risks related to (i) fraud and brand identity; (ii) social media vendor monitoring; (iii) privacy; (iv) consumer complaints; and (v) employee use of social media. Finally, the guidance addresses the vulnerability of social media to malware and the resultant operational risk. The FFIEC is accepting comments for 60 days after publication in the Federal Register. After the comment period, the agencies will issue supervisory guidance and will urge state regulators to follow.
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Topics: Barack Obama, CFPB, Electronic Notarization Standard, Eminent Domain, FHFA, Fraud Exception, Mortgage-Backed Securities, Mortgages, NCUA, NLRB, OCC, Parol Evidence, Permits, Recess Appointments, Richard Cordray, SEC, Social Media, TILA
Published In: General Business Updates, Consumer Protection Updates, Finance & Banking Updates, Residential Real Estate Updates, Securities Updates
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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