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New Forms of Marketing

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Question: 
We have employees who have joined Facebook, Twitter, Linkedin and the like. These are social networking sites and what employees do on their own time is their own business. Are we responsible for advertising compliance if they solicit business in these sites, as they strive to make new accounts goals?
Answer: 

Yes. When they represent the bank, they are subject to the advertising requirements. This is no different than an employee setting up a personal website and using it for banking business.

You might be able to argue with a regulator and avoid a cite, requiring that the offending content be corrected or removed, but if a customer sued, the bank's name would surely be involved. It is your product and service, you would enjoy the benefit of the account and you have the deep pocket. Employees should be trained to separate their personal and business lives as they could pose a risk to the bank.

First published on BankersOnline.com 5/04/09

First published on 05/04/2009

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