We have some lenders that are using LinkedIn to state information about themselves and what kinds of loans that they do at the bank. They also have a link to our bank's website. Should I be concerned about this? If it was an ad I would say it needs to have the EHL logo since the lender is talking about mortgages but it seems like this is more of a professional version of Facebook. Any insight is appreciated. Thanks!

Wihtout seeing how the pages are set up that sounds very close to an advertisement IMO as the loan officers are representatives of the bank. Also did the bank give permission for the loan officers to set the link? If the bank is condoning this then I think one could easily consider it an advertisement. Just my 2 cents worth.

If this arrangement amounts to ads, then you will need to commit the resources necessary to monitor what's going on. The doghouse is obvious, but keep the more serious potential problems in mind too: prescreening/exclusive image, Section 8, etc.

I would like to resurrect this thread to explore the potential section 8 implications of using LinkedIn. Since the obvious goal of using LinkedIn is to grow a loan officer's book of business, when you recommend a person you are connected to who is a provider of settlement services, wouldn't this referral be a "thing of value" and thus automatically constitute a section 8 violation?

Also, Richard, could you please expand on your reference to "exclusive image"...I don't know what you mean.

Bump

Not Richard, but I am sure he was referring to this - search the document for exclusive images:

http://www.federalreserve.gov/boarddocs/supmanual/cch/fair_lend_fhact.pdf

As far as Section 8 goes, you need to perform a complete risk assessment for use of social media for bank purposes and then develop your procedures regarding what is and is not allowed. Recommending specific service providers may well be subjecting the bank to Section 8 issues depending on how it is done, how are these vendors vetted by the bank prior to a recommendation being made, who makes the decision on who is recommended, who reviews the specific social media pages to ensure advertising rules are adhered too, etc., etc.

Picking this up again...these are not vendors, but rather real estate agents on Zillow who may want to refer our loan officers or be referred by our loan officers. To me this flys in the face of section 8...even though technically nothing of value is exchanged, isn't the referral itself a thing of value?

I see this as the same as it's alwasy been jsut a little more out in the open. Lenders and realtors get chummy and refer customers to each other. The referral is not the issue, it's whether the referrer gets something for that referral. I don't use Linkedin or know how it works but I suppose if there is some type of lender link or section on the realtor's page or vice versa, then that could be considered a thing of value; similar to the lender flyer in a realtor's open house situation.

One of the black holes when venturing into the realm of social media.