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Compliance Question of the Week
In today’s banking environment as soon as one big new regulation is implemented another pops up. Our compliance resources help your community bank stay one step ahead of the regulators.
If the bank is using social media or texts to communicate with students about loans, does the bank need to be concerned about cybersecurity if the messages aren’t personal?
ANSWER:
Yes. Although the texts aren’t personal, i.e., the texts don’t include any account information, cybersecurity is always a concern. For example, if a hacking incident occurs, does the bank have in place procedures to respond; to ensure that those affected are notified; to ensure that those who regularly receive the texts know that it is not the bank but a hacker requesting information.
In addition, the bank needs to be aware of compliance regulations that may pertain to social media messages e.g., in the context of student loans – Regulation Z and any advertising requirements that may apply; FCRA; Reg B and fair lending to guard against discrimination; privacy laws; and information security, consumer complaint response, etc. In addition, a consumer complaint process should be established.
Reference: Regulation Z: 12 CFR 1026.24; 1026 Subpart G Fair lending and Regulation B: 12 CFR 1002 Regulation P (privacy): 12 CFR 1016 Information Security Guidelines Fair Credit Reporting Act. See also: FFIEC: Social Media; Consumer Compliance Risk Management Guidance, 2013. FFIEC IT information Security, 2016