Letters

FFIEC Social Media Guidance

Summary

SIFMA provides comments to the Federal Financial Institutions Examination Council (FFIEC) on the proposed guidance, Social Media: Consumer Compliance Risk Management Guidance, Docket Number FFIEC-2013-0001

Addressing the FFEIC’s question of other consumer protection laws, regulations, policies or concerns that may be implicated by financial institutions’ use of social media, SIFMA pointed out:

“FINRA and the SEC’s Office of Compliance and Inspections and Examinations have already published guidance on the use of social media. The social media guidance published by FINRA and the SEC is tailored to the specific regulated activities applicable to the covered entities. SIFMA is concerned that those of its members that are subject to Board oversight also may be subject to the Council’s Guidance resulting in duplicative and potentially conflicting regulatory guidance. To avoid unnecessary duplication, confusion and conflict, SIFMA encourages the Council to expressly exclude Securities Firms from the entities subject to the final Guidance adopted by the Council.”

 

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