MCUL Provides Input on the FFIEC’ s Proposal for Social Media Risk Management Guidance 

On March 25, MCUL & Affiliates provided its comment to the Federal Financial Institutions Examination Council on its proposed guidance for Social Media: Risk Management.

The MCUL comments stressed the current burdens new regulations have placed on credit unions and emphasized that additional strict requirements on social media will make it unlikely for credit unions to consider developing and utilizing social media strategies to enhance member communications.

Click here to read the FFIEC’s proposal, Social Media: Consumer Compliance Risk Management Guidance. Click here to read the league’s comment letter.

MCUL strongly opposed the proposed requirement to manage the risk of Internet gaming and virtual currency transactions that are not conducted within the current federally regulated financial services industry. Additionally, the MCUL opposed additional third-party due-diligence requirements that duplicate current NCUA requirements.

The FFIEC included in its proposal requirements for risk-management planning, procedures and responses for negative comments posted to social media sites that could have a negative impact on a credit union. MCUL stated that credit unions should not be responsible or liable for the actions of the general public.


Submissions to Monitor may be emailed. Bryan Laviolette is the editor of Monitor. Contact him by email or call (800) 262-6285, ext. 233. The newsletter of the Michigan Credit Union League is published Monday mornings or Tuesday mornings when Monday is a holiday. There is no Monitor the week after Christmas and the week after the Annual Convention and Exposition. The MCUL reserves the right to edit submissions for clarity and space.
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