Pub. 2 2012-2013 Issue 6

12 O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S FEATURE ARTICLE “With inevitability in mind, it’s important to perform a risk assessment and establish controls for social media, regardless of your level of involvement.” Virtual Life: Automatic Enrollment T heFederal Financial InstitutionsExamination Council (FFIEC) recently released proposed guidance on social media. The proposed guidance, titled Social Media: Consumer Compliance Risk Management Guidance , identi fi es risk management expectations that could surprise bank personnel who are not very familiar with the scope of social media. Generally, you perform a risk assessment for services you offer. But social media is a com- pletely different monster of its own. I would categorize it more with tornados and fl oods. In other words, risk from social media is in- evitable even if your bank speci fi cally chooses not to use it. With inevitability in mind, it’s important to perform a risk assessment and establish controls for social media, regardless of your level of involvement. We would like to think that we are in control of what happens to our bank at all times. The truth is: we can’t control everything, which is why we do things such as perform risk as- sessments, assign policies, and accept some risk. We can’t control the world around us, so we do our best to put up suf fi cient defenses, which we like to call controls. What defenses do we have in place for the virtual world? Just as a person can freely start up a conversation about anything they want, they can also start a virtual dialog about any topic. But a virtual dialog has the potential to go viral, and there is no erasing or going back from that. Anyone LETICIA SAIID Software Support Specialist CoNetrix