Jordan's conclusions are straightforward make sense. It is no secret that the major advantage of social media, in general, is the ability of companies to develop conversations with their customers and prospective customers.
But what about the supporting aspect of social media - particularly as it relates to banking?
Let's examine how banks support customers in the traditional sense. The basic support activities include:
- Answering questions regarding products and services.
- Establishing products and services.
- Addressing complaints regarding products and services.
- Informing customers of new products and services.
- Notifying customers of changes to products and services.
Now let's see how this could work (or not work) using Twitter.
ANSWERING QUESTIONS REGARDING PRODUCTS AND SERVICES
Using Twitter, banks can definitely utilize Twitter to address product and service questions. A typical exchange can look like the following:
@BankCustomerService: Do you offer any free small business checking accounts?
@SmallBusinessGuy: Yes. With $500 min mnthly bal. Restrictions apply. See http://bit.ly/1234. FDIC-insured.
@BankCustomerService: What is your 12 month CD rate?
@CDConsumer: 12 mo CD under $100,000 has 1.00% Annual Percentage Yield. Rates subject to change. See http://bit.ly/1234. FDIC-insured.
@CDConsumer: 12 mo CD $100,000 and over has 1.15% Annual Percentage Yield. Rates subject to change. See http://bit.ly/1234. FDIC-insured.
@BankCustomerService: Do you offer 30-year mortgages and what are your rates?
@MortgageSeeker: We offer many types of home loans. Pricing is based on many factors. Call us at (888) 123-4567 to discuss options specific to you. Equal Housing Lender.
@BankCustomerService: Do you have a branch close to Main Street?
@LivingOnMainStreet: We have branches throughout the city. Use our branch locater at http://bit.ly/1234. FDIC-Insured.As you can see, Twitter can be effectively used to address product/service questions. Some challenges appeared in the few exchanges above:
- Disclosures: Depending on the nature of the exchange, certain disclosures will need to be provided with each exchange. The most common disclosures involve compliance with Regulation Z (Truth in Lending), Regulation DD (Truth in Savings), Fair Housing Act and FDIC Rules and Regulations. Whoever is tasked with responding to tweets will have to have a strong understanding of consumer disclosure regulations. The best bet is to ensure that the individual has heavy compliance training and has prepared scripts for the most common questions that are blessed by either the Compliance or Legal Department. Any response outside of the scripts should then require prior approval.
- @ vs DM: When responding to questions, the bank should consider whether to respond openly or through a direct message. A DM provides a confidential response. While this may seem appropriate, it does not allow others to benefit from the response. Either approach is appropriate...unless there is discussion of any nonpublic personal information. WARNING: Do not discuss nonpublic personal information. That is a regulatory violation of Section 501 of the Gramm-Leach-Bliley Act waiting to happen. Keep all info free of such information. If you receive a tweet (or any electronic communication) with that information, immediately inform the customer to avoid issues.
- Working the Desk: Today's consumers are no longer 9 to 5. Today's consumers work up until they hit the sack. That means it would not be unusual for consumers to tweet a product or service question at 1:00 am. The worst part...they expect a response. So unless you have a 24 x 7 call center addressing tweets, you need a solution on how to handle after-hour tweets. At a minimum, the bank should set up some form of auto-response service that let's the consumer know that a response will come the next business morning. Use Google to find programs available to manage this and other administrative Twitter functions.
- Record Retention: Most banks maintain some form of record retention policy regarding customer communication. It would be prudent to discuss tweeting with the individual responsible for ensuring compliance. This is usually the Legal, Risk Management or Compliance Department. Based upon the results of the conversation, the bank will next need to develop procedures to capture and archive such communications. Again, it is recommended that you seek out some form of third party application that contains archival capability. In addition to complying with record retention policies, the bank's regulators may ask to see the communications as part of their advertising/marketing compliance procedures.
- Social Media Policy: Once answers to the four items above are determined, the bank needs to put together a Social Media Policy. Not only is this required to ensure employees do things the right way but regulators will also likely require that the bank maintain a comprehensive social media policy that addresses all the regulatory requirements noted above.
ESTABLISHING PRODUCTS AND SERVICES
If you are familiar with social media and its nuances you have learned that social media is not the most effective platform for selling products. Users of social media generally do not want to be "sold." Users of social media want to be part of a community that they can learn from and share with. "Becoming part of the conversation" is commonly used to describe social media participants. Having said that, banks should take advantage of opportunities to sell. For example, when responding to inquiries, banks should respond with links that not only provide the answers but that also provide the opportunity to open an account. Of course, this requires that banks provide consumers with the opportunity to open accounts online - which all banks do not.
The natural tendency is to respond to complaints privately. No company necessarily wants to air its dirty laundry before the world. But hold on a minute. One of the advantages that social media provides is the ability to create a maintain conversations. Conversations can come from many sources. But conversations that begin with complaints are the best kind. Huh?
Social media allows banks to become more transparent. By being upfront and honest about making a mistake and addressing the issue promptly and head on, banks can go a long way in gaining the respect of consumers - particularly in today's banking environment. Everyone and every company makes mistakes. What everyone does not do is admit to the error and do what it takes to cure it. When consumers see a bank step up and do the right thing, it goes a long way in gaining the respect...and business of consumers.
So, going back to the question of public or private response. Rule #1: if you are questioned privately (DM), respond privately. Rule #2: if the response involves any personal information, respond privately. Rule #3: if the response relates to a violation of a law or regulation, refer to Legal for response. In this case it is important to protect the company from parties that would seek to use the bank's spirit of transparency against it through some form of legal action. Regardless, let the consumer know PRIVATELY that a response is coming. Rule #4: all other responses should be responded to publicly.
Similar to the scripts used for product/service questions, the bank should have a set of scripted responses approved by Legal and/or Compliance. Any response outside of the preapproved scripts should be sent to Legal/Compliance for review.
NEW PRODUCT/SERVICE ANNOUNCEMENTS
As noted above, social media is not the best place to make overt sales pitches. The unwritten code of social media is that interaction should have some community benefit. That does not mean, however, that new product launches should not be mentioned in tweets. It does mean that you have to find a creative way to do it. As I said, information shared is expected to be of some benefit to the community. This explains the large extent of retweeting (RT) of links and other information. It has become extremely common to retweet links to articles that might seem useful to followers. As such, if a new product/service launch can be molded into a form that provides benefit then by all means share.
For example, take a bank that in an effort to increase its visibility within the local nonprofit community, begins offering use of its conference room free-of-charge to local nonprofit organizations. This service could be shared as a tweet that references a Web page or press release that provides the details. Similarly, new products that can be shown to provide some benefit can be marketed in a similar manner. The idea is to not come off as just selling a product but instead as providing benefit to the community.
CHANGES TO PRODUCTS/SERVICES
Unfortunately, due to regulatory requirements, banks cannot rely on tweets to get the word out regarding changes...exclusively. However, as noted above, consumers expect to receive beneficial information through social media. As such, Twitter could be used to: 1) survey customers about proposed changes, 2) inform customers about changes (in addition to what is required by regulation, which is usually 15 days notice in writing), and 3) provide links to updated terms and conditions associated with the affected products/services. While the information provided through Twitter cannot be relied upon to meet the regulatory change in terms requirements, it can provide useful information in a form that many prefer to receive.
From the information contained here, it looks like Twitter can definitely be used to support customers. Unfortunately, support is not as easy as banks may like it. As a highly regulated industry, bankers need to ensure that all communication is compliant. Therefore, any social media plan should include not only the use of an experienced social media professional but a regulatory/compliance professional as well. And above all, get a social media policy in place.