The Federal Financial Institutions Examination Council (FFIEC) has released final supervisory guidance on the use of social media by financial institutions. We last reported on the guidance when it was published in draft form in January 2013. The final guidance is substantially similar to the proposal (and we encourage you to read our prior post for more details on the elements of the guidance), but the FFIEC made certain revisions in light of the 81 public comments it received on the proposal.
This blog entry provides a summary of the Hogan Lovells Chronicle of Data Protection’s recent coverage of legal developments regarding social media.
The Hogan & Hartson privacy lawyers are counseling clients on the use of social media, as the legal risks are significant — especially if employees use the shield of anonymity to protect their privacy but make representations on behalf of their employers without disclosing their affiliation. The FTC and FDA recently have focused on social media. And on January 25, the Financial Industry Regulatory Authority (FINRA), an industry self-regulatory organization, issued Regulatory Notice 10-6, which gives guidance to member companies on the use of blogs and social networking sites to engage in company-sponsored communications with the public.