The FFIEC has urged financial institutions to monitor social media, without explaining how to do that, how much monitoring is enough, or what to do with the resulting information. There are no “rules of the road” yet. Mortgage lenders are feeling their way in the dark.

The point of monitoring is to analyze the risk of content that lenders or loan officers place on Twitter, Facebook, YouTube, and other social platforms. Meaningful monitoring can help protect brand identity, identify employees adept at driving business through social messaging, and support regulatory compliance.

Consider some potential uses of social media monitoring in the home mortgage industry. Let’s say a lender has geographically-dispersed loan originators in branches around the country. Assume half of them use social media to generate loan applications. Comparing the origination results of LOs with an active social presence with their less connected counterparts may reveal whether social media-generated loan inquiries or applications exceed those achieved via traditional origination methods. Eventually, the quality of the actual loans may be evaluated by origination channel as well, helping the lender evaluate whether social media promotion provides a “bang for the buck,” vis-a-vis other channels.

Monitoring could also reveal which social media apps work best in different parts of the lending territory. Think about this: If Texas LOs message with their customers primarily via Twitter and Florida LOs concentrate on LinkedIn, comparing the officers’ performance could help the lender refine its social media strategy.

If most of the company’s loan originators use social media to solicit mortgages, but marketing success is concentrated, monitoring the messages of the influential LOs could help identify those who are generating relevant, productive content. The “influential posters” might be good candidates for providing social media training to other LOs, or for advising management on effective social strategies. Or, it might be time to give them a raise … before the lender’s competitors catch on (because top creators of social content are courted within their own industries and by YouTube and Facebook, which sell that content to advertisers, sometimes sharing ad revenue or offering goodies like use of studios, stages, or video production equipment).

On the customer relationship management front, a lender could monitor and analyze how LOs deal with problems, criticisms, or complaints on social platforms. If more consumers gripe on Yelp about New Jersey loan officers than their New Hampshire counterparts, for example, a lender could focus its training and target customer service improvement efforts to those with high-dissatisfaction social feedback.

Mortgage lenders’ enterprise-wide compliance efforts might also benefit from social media monitoring. Searching and analyzing keywords like “worst bank” or “predatory rates” (or other negative buzzwords) within loan officers’ or mortgage brokers’ social messages could predict or anticipate regulatory scrutiny while simultaneously pinpointing the source(s) of the problem. If noncomplying messages (e.g., posting loan rates without corresponding APRs) are identified by individual poster, a lender could offer targeted remediation or training efforts. As many advertising rules prohibit use of specific types of messages (unqualified superlatives, for example), monitoring could easily identify violations, and violators.

Social media monitoring can also promote fraud detection. Intentional misrepresentations can flourish on social platforms. Undisclosed compensation for positive social posts is unlawful, but not unknown. (See the FTC’s Endorsement Guide, updated in May). A loan officer may try to improve his digital reputation by paying for secret positive posts. Monitoring unusual upticks in the volume of customer raves about specific loan officers might unveil endorsement “violators.”

As social media gains ground in the home mortgage space, lenders should consider the benefits of analyzing posted content by employee. The results may lead the company to redeploy people and/or resources, and help nip emerging compliance problems in the bud.

Archived social messages can be both a regulatory weapon and a defensive shield. If a compliance problem is revealed through monitoring of archived messages, the ability to identify the source of the messages may help isolate the problem and contain the consequences.