Maj. Charles Emerson Winchester III, M.D., learned the hard way his first day at fictional 4077th Mobile Army Surgical Hospital, “M*A*S*H.”
“I do one thing at a time, I do it very well, and then I move on,” he snobbishly intoned moments before his introduction to what Capt. Benjamin Frankin “Hawkeye” Pierce called “meatball surgery” just off the front lines in Korea, 1950-1953, which, of course, was 61 years ago.
The episode was “Fade Out, Fade In,” sixth season, 1977, which was 37 years ago.
All of which comes to mind on news that banks and other financial institutions now have “consumer compliance risk management guidance” for social media, which started — stay with me — oh, at least 15 years ago, with Blogger in 1999.
Since then, social media has become as ubiquitous as wristwatches used to be: LinkedIn, 11 years ago; Facebook, 10 years ago; YouTube, nine years ago; Twitter, eight years ago — and so many now I don't know anyone who keeps up with them all.
Clearly, the interagency Federal Financial Institutions Examination Council (FFIEC), promulgator of the social media guidance, does “one thing at a time ... very well, and then ... move(s) on.” One wonders just how many consumers — and financial institutions — stumbled into meat grinders among the meatballs and goofballs on social media.
Not to pick on the FFIEC too much. Who knew, who could possibly have known, that social media would become what it has become?
Who knows how much harm has been done just in the sheer still-newness and ubiquity of it all? Better late — if it is late — than never.
In a nutshell, “to the extent that a financial institution uses social media to engage in lending, deposit services, or payment activities, it must comply with applicable laws and regulations as when it engages in these activities through other media,” the FFIEC said.
In other words, social media is part of “the media.”
Here are some of the laws and regs involving real estate and social media that financial institutions, and y'all, need to know about:
• Fair Housing Act.
Among other things, the act prohibits discrimination based on race, color, national origin, religion, sex, familial status, or handicap in the sale and rental of housing, in mortgage lending, and in appraisals of residential real estate.
Directly to the point for media, social or otherwise, the act makes it illegal to advertise “or make any statement that indicates a limitation or preference based on” those characteristics.
Read all about it: www.ffiec.gov/press/pr121113.htm.