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Should Compliance Be Reviewing Officer Blogs?

We have a couple of tech-savvy lending officers who regularly post to personal blogs. We have a policy requirement that their blogging must include disclaimers that they are expressing personal opinions only and not writing on behalf of the bank.However, occasionally they may mention a bank product or service ("My bank offers a 35-year fixed rate loan" appeared in one of the blogs last week). Can their blogs be considered advertisements with trigger terms and compliance issues for the bank? Do we have to control what they post?

Answer by John Burnett:Statements like the one in your question certainly don't appear to be opinion. They appear to be statements of fact, and the officer is touting a product that you purportedly offer. The question I'd first ask is whether the blogging officer is identified in the blog as connected to your bank. It's often the case that the affiliation is given to add credibility to the blog. If the connection is revealed, I think you've got an ad on your hands, and one that includes a trigger term, at that!

There is nothing inherently wrong with ads in blogs and other social media. However, your bank should have a clear understanding of the risks involved in the use of social media, and your employees who use those media should be given firm guidelines and have accountability for adhering to them. One of the key requirements should be that any statement to be made concerning the bank's services or products should first be approved by your marketing department and/or compliance officer.


Answer by Richard Insley:If you don't have the resources to review and approve all the electronic content your sales force wants to post all over the Internet, you may need to add resources or restrict this kind of informal advertising.

First published on 7/26/10

First published on 07/26/2010

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