Compliance and Social Media

Posted By Anthony Demangone

Here's a thought-provoking blog posting from the Bank 2.0 blog about how compliance and social media interact.  The author argues that compliance divisions need to learn how to say "yes" more often.

Compliance needs to understand the negative risk of increasing workload on the frontline in respect of customer service perception, and decreasing the ability of the organization to respond to social media events in real time. They need to start thinking about their function as an enabler of the core business with customers, rather than just risk mitigation. They can also be lobbying regulators to help regulators adapt and make their processes more user-friendly, while retaining security of identity and the assets of the customer.

Customer experience is being hampered by compliance heavy processes that look to reduce risk, but make the engagement unnecessarily complex. Translating the Terms and Conditions from a paper application form onto the first 7 pages of a web-based application process might seem legally sound, but is quite ridiculous from a Usability and Customer Experience perspective.

If you look through the comments to the posting, you'll see where I stand.  I fired off a semi-cranky, response at 11 p.m. last Thursday.  I'm not sure that the author truly understands that certain disclosures and practices are legal requirements.  That being said, there might be a lesson here. 

1. Do we communicate to our "customer base" why we take our positions?  Are we saying no out of a gut reaction, or out of clear legal or regulatory mandate? 
2. Do we start out by saying no, and then look for ways to support that decision?  A better way of approaching an issue is to do the necessary research and see if there is a way for something to be done in a legal way. 

In any event, an "us versus them" mentality between compliance and marketing staff will accomplish little.  Everyone needs to be on the same page for the process to work well. 

Comments

[Blane Warrene]

The challenge here is that the conversations our customers are having has shifted to social media - and they are finding ways to discuss financial institutions with or without those institutions listening. Likewise - many customers have chosen to move to organizations that have found a way to balance the legal requirements with the need to continue engaging the customer - especially the new emerging customer that will be the high net worth client in the next decade. Those emerging clients are markedly web 2.0.

I do not think it is a question of marketing stating compliance needs to get with it - it is marketing letting compliance know they are leaving valid client relationships on the table by not seeking ways to strike a balance between the often ambiguous regulatory guidelines and customer demand.

[Brett King]

Anthony,

Thank you for engaging in the discussion. I have no problem with the legal and regulatory frameworks that require compliance, I'm just advocating that the role of compliance is ultimately to protect customers first, shareholders second and employees third (probably).

In that respect, compliance is at a tipping point right now where the rate of innovation is frantic. Coping with the changing customer experience requirements is a nightmare unless you are really on your game. But most certainly the answer is not to fall back on old processes or old internal policies and try to enforce those, when clearly the environment within which those processes or policies were founded operationally has completely morphed.

Compliance departments need to become the cutting edge of consulting around how to protect the customer, while simplifying the engagement. This problem is not going away, and customers definitely will not revert their behavior to make compliance departments more relaxed. The fact is that we need to embrace the change, and compliance departments need to be the enabler. In my experience it's just easier for compliance officers to say no - than think about how a 'yes' might work in the new environment.

That's all I'm asking for - we know you have to mitigate risk to the organization, but first and foremost you have to be there to enable the customer experience safely. That can't be done in isolation of technology innovations, it has to be integrated through new thinking.

Regards,

Brett King
Author - BANK 2.0