Organizations using social media are confronted with an ever increasing challenge of social media risk management. To help financial institutions identify, measure, monitor, and control such risks, the Federal Financial Institutions Examination Council (“FFIEC”) has just released proposed guidance (the “Guidance”) on the use of social media by banks, savings associations, credit unions, and nonbank entities supervised by the Consumer Financial Protection Bureau and state regulators.

The proposed policy (entitled Social Media: Consumer Compliance Risk Management Guidance) defines social media broadly to include any “form of interactive online communication in which users can generate and share content through text, images, audio, and/or video” and therefore captures micro blogging sites such as Google Plus, Facebook, MySpace, and Twitter, photo and video sharing sites like Flickr and YouTube, professional networking sites like LinkedIn, and online forums, blogs, bulletin boards, customer review sites, virtual worlds, and online social games.