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#2245384 - 11/10/20 06:46 PM Social Media post by employess on behalf of Bank.
TaraTLR Offline
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Posts: 142
When employees communicate officially on behalf of the financial institution are they bound by the same regulations as the financial institution? By this I mean, when they promote the Bank on a social media site do they need to use the Member FDIC and Equal Housing Lender logo's (as applicable) in their posts?

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#2245387 - 11/10/20 07:08 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
Skittles Offline
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Skittles
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TN
It would be an advertisement and all disclosures would be required. This is why most banks do not allow employees to post anything on their social media pages about products or services.
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#2245440 - 11/12/20 05:30 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
TaraTLR Offline
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If the individual posting on the Bank's behalf were to include a link to the Bank's website with the required disclosures, would they still be required to state "Member FDIC" or include the Equal Housing Lender logo in the post? Especially if there is no picture?

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#2245441 - 11/12/20 05:41 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
rlcarey Online
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rlcarey
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Galveston, TX
Most bank's prohibit employees from making such posts and only your marketing department controls all social media content. If an individual posts on behalf of the bank, then whatever they post stands alone from an advertising perspective.
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#2245443 - 11/12/20 06:10 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
TaraTLR Offline
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Would you mind clarifying your statement "stands alone"? Would this mean they don't have to abide by the regulatory disclosure requirements?

Let me give you an example. Some of our Bank Officers have taken to LinkedIn and Facebook and are promoting the Bank and sometimes its specific products. These are not comments in regards to a Bank posted ad, just their statement on the social media site. They are also not using any verbiage that indicates that " this is their opinion and not a representation of the Bank" So, from a readers standpoint they look to be a representative of the Bank. Am I wrong to think that they are bound by all the advertising regulations?

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#2245444 - 11/12/20 06:18 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
These types of posts are absolutely governed by all the advertising regulations which is why Randy recommends having a social media policy that limits this type of content to bank approved sites and accounts and forbids employees from posting this type of content. Otherwise, how can marketing and compliance monitor every employee or approve every post?
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#2245446 - 11/12/20 06:21 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
Skittles Offline
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Skittles
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TN
And depending on what the loan officer posts, this could get more complicated than just posting 'Member FDIC' or 'Equal Housing Lender'.
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#2245448 - 11/12/20 06:22 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
TaraTLR Offline
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Would a link to the Bank's website with the Member FDIC and Equal Housing Lender logo's and any other disclosures be compliant with the regulations?

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#2245449 - 11/12/20 06:31 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
rlcarey Online
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rlcarey
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Galveston, TX
There are no one-click rules for those disclosures
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2245475 - 11/12/20 10:38 PM Re: Social Media post by employess on behalf of Bank. TaraTLR
TaraTLR Offline
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Joined: May 2013
Posts: 142
Thank you everyone for your expert advice. I greatly appreciate it.

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