Four Steps to Social Media Plan

I just finished reading Courtney Spencer's "Implement a Social Media Marketing Plan with These 4 Easy Steps."

Courtney minimizes the process to four basic steps:

1. Decide Where Exactly You Want to Be Online
2. Come Up With Multiple Options
3. Implementation
4. Search the Web

All in, I think Courtney did a good job of summarizing the basics. I would have liked to see a little more meat, particularly on the Implementation stage. But all in, not a bad summary.

If I had to focus in on one area, it would be the sections that speak to the resources needed to "maintain" the effort. Unlike other marketing channels that may be somewhat forgiving, social media is one that can truly require anywhere from weekly to daily to hourly effort once the campaign is launched. The media is so fluid and interactive that ignoring it could result in lost opportunities or reputation risk. Think Community Manager when you roll out an effort to ensure you give the appropriate attention to the plan.

Give it a look and provide Courtney your two cents.

How Effective are my Tweets?

By now even the most conservative bank CEO has heard of Twitter. And in some cases, these CEOs have asked the marketing department to build a Twitter following to drive traffic to the bank's Web site.

One problem most bank marketers face when tweeting messages is determining how effective the tweets are in driving traffic to a Web site. A bank may have hundreds, thousands or even tens of thousands of followers. However, simply having a large following does not mean that a bank's tweets are getting face time with followers that result in click-throughs. As such, a bank needs a process to measure tweet-effectiveness (TE). I am going to describe two similar but distinct methods of determining TE.

The first method involves using a URL shortener with built-in tracking such as bit.ly. This tool allows you to accomplish a couple things. First, bit.ly allows you to create a short URL to the Web site you are seeking to promote. For example, a URL such as widgetmaker.com/12345/widget.asp can be reduced from 33 characters to bit.ly/1234 or 11 characters long, saving 22 of the 140 characters available for use on Twitter.

Second, use of a URL shortener with built-in tracking then provides the bank with some basic analytics such as clicks, referrers, locations, etc.

The availability of the analytics allows the bank to determine the TE by examining the click-through data for the link created using the URL shortener. Another upside is that this functionality is currently free to users.

There is a downside, however, to the use of URL shorteners. The first and most obvious downside is what happens if the URL shortener goes out of business or is hacked and all links die or get redirected to another site. To the extent that the TE was good and producing favorable results, the death of the site or a hack may have a devastating effect on not only conversion but potentially creates reputation risk if a bank link is redirected to a porn site or site containing malware.

Therefore, depending on the risk appetite of the bank, a bank can replicate the URL shortener process in-house. By either using the bank's current domain or setting up a shorter domain that is controlled by the bank, the bank can create similar links to those created by bit.ly or other URL shorteners. The bank simply utilizes the "redirect" function available on the Web server. The bank would then utilize its own internal analytics software or rely on a public application such as Google Analytics to track click-throughs.




The second option, while more secure, is also more cumbersome. Increased coordination between IT and marketing must occur every time a new tweet is developed for tracking. IT must create the link and redirect code to ensure that the bank-generated shortened URL points to the proper Web address. Depending on the organization, this may or may not be the smoothest task to accomplish.

Regardless of the option selected, any process that involves the circulation of a Weblink should involve a procedure to measure the effectiveness. Here we used Twitter as the example. However, the same approach applies to the use of Facebook, MySpace or even an email blast.

Duality of Social Media in Banking

With banks working double time to squeeze value out from every last penny, many bankers are taking a closer look at social media and the value it can bring to an organization.

For about a year and a half references have been made increasingly regarding MySpace and Facebook and how businesses can appeal to the masses that visit these sites. Then a couple weeks ago it all broke loose when Ashton Kutcher battled CNN for the first to hold one million followers on Twitter. And then it happened, the tipping point, the day everything changed. The day Twitter became a household word.

Since that day I have been approached by banker acquaintances asking me how they can use Twitter to make them heroes. And in these discussions I found the duality of social media.

The banking industry is one of a handful of industries that is overly regulated and becoming more so every day (thanks TARP!). While bankers see the benefits of using Twitter and social media, they often find it very difficult to get past the associated risks. On the other hand, bankers make their living dealing in risk. As such, it would appear to me that banking is one of only a few industries that is well suited to incorporate the use of social media, warts and all.

So to my banker friends I say, get over it and do what you do best - assess your risks. The first step in any new bank product/service launch is the risk assessment. Risks can originate from the statutory liability and regulatory penalties that are specified by law, or from reputational damage that could result from publicity of noncompliance (see Social Media and Bank Compliance Requirements). Once you get your arms around the risks and feel warm and fuzzy about dipping your ties, get to it.

Of course, as with any implementation, you must have a plan that is well thought our and clearly defined. This involves doing your homework. Speak to experienced social media practitioners by researching them on the Web or meeting them at social media conferences, see what the competition is doing, see what other industries are doing, read The Community Banker's Guide to Social Network Marketing (disclosure: I wrote this free ebook), get the green light from the right people and put your team together.

Unfortunately, today, everyone is still largely feeling their way around. The use of social media in a commercial setting has only just begun. However, there is a large global community that actively supports this effort. So, while the model has not been entirely proven, the successes to date, the support network and the masses of consumers taking to social media should make dipping your toes at least something to consider.

Anyone up for a swim?!

Banking is Our Business, and We Think Our Business Needs to Be Wherever People are Talking About Banking

"Banking is our business, and we think our business needs to be wherever people are talking about banking."

The quote above was provided by Peter Aceto, CEO of ING Direct Canada in an interview with Bank Technology News Magazine. Mr. Aceto, an active tweeter, expresses an opinion held by many "enlightened" bankers. But banker beware: if you build it, they may not come.

Rebecca Sausner says "just because there are millions of people at a concert doesn't mean they want to see a banker take the stage." This is a great point. However, I would counter her by saying that banks should have some form of presence for the ocassion in which a client or potential clients needs to reach out. It is during those opportunities that banks will earn the points that put them over the top in the hearts and minds of consumers.

I am a tremendous fan of social media and the many benefits it brings to the banking environment. However, I recognize the many nuances that need to be considered in developing and implementing a social media plan. I agree that a bank's place within social media is not in-your-face. In fact, that is probably the last thing you want to do. Having said that, there are many ways in which banks may leverage social media while playing a role in the background and staying prepared to pounce on opportunities as they come up.

A good example is Bank of America's social network for small business operators. Bank of America has created a space on its dime that draws customers and non-customers together to share ideas and leverage from each other. As conversations take place, BofA is prepared to jump in to provide answers. Also, BofA is along the way collecting information that will assist in the development or improvement of new products and services. So, going back to Rebecca's analogy, while BofA may have built the stage, they are not on the stage but are instead backstage prepared to deal with any questions that may pop up as well as out in the stands listening to the crowds reactions.

Rebecca also made a point about the current financial viability of social media platforms such as Twitter, Facebook, et al, and whether their inability to create income is worthy of steering clear. My immediate response is "so what!" Applications like Facebook and Twitter are drawing in batches of people by the millions. Banks should do what they can to leverage their brand. However, banks should also be sure that their commitments take into consideration the fact that a specific platform or the social network/media industry as a whole may dramatically change over time. But the fact the Twitter may be here today and gone next year should not keep me away from taking advantage of the asset (e.g., people). I just need to make sure that my return in consistent with the investment made.

I think Rebeccas was spot on when she said, "the larger point is that understanding your customers is key. If your customers are addicted to Facebook, texting, tweeting, or LinkedIn groups, you should at least have first-hand knowledge of how and why. " That's pretty much it in a nutshell. Know your customers, know what makes them tick and you'll be able to appeal to them and develop products and services that they will be unable to live without.

For more information on the nuances of social media, download a free copy of The Community Banker's Guide to Social Network Marketing.

Social Media Lowers Stress Over Stress Tests

On May 4, 2009, the government will publicly release a portion (very little portion) of the results of the stress tests conducted by regulators at the 19 largest U.S. banks. The 19 banks have already received the results and will have the opportunity to respond to the findings of the tests on May 4th.

According to Congressional testimony by Treasury Secretary Timothy Geithner,

"one of the major components of the Administration's Financial Stability Plan (FSP) is the Capital Assistance Program (CAP). The CAP is designed to ensure that individual banks have sufficient capital even in adverse circumstances. This strategy begins with the idea that in order to ensure our largest banks have adequate capital to weather a more severe economic scenario and continue to lend, we must first accurately diagnose their problems. Federal banking agencies will soon complete a forward looking assessment or "stress test" for the 19 largest banks. The stress tests will determine the capital needs of these banks by estimating losses that they might face if economic conditions were to deteriorate more than expected over the next two years, as well as the appropriate level for loss loan reserves at the end of the period. The analysis will take into account the likely path of earnings for individual banks over the same period. By focusing on individual banks, this approach allows the analysis to take into account the unique exposures that individual banks face as well their individual prospects for generating earnings."

While many believe that all 19 banks will "pass" the tests, there is still likely to be some adversity and the government will, regardless of the outcome, likely ask some or all of the 19 banks to beef up their capital levels.

The release of information will prompt the media and consumers to elevate discussion of the capital adequacy of ALL banks. As this occurs, more and more chat will take place relative to non-stress test banks and their capital adequacy. As such, it will be critical and a perfect opportunity for all banks to monitor conversations occurring on the Internet that specifically involve them as well as general consumer concerns regarding banks. We saw this happen in mid-2008, after the crash of IndyMac Bank. This is likely to spark a second round.

On April 10th I posted Banking Regulators Should Make Use of Social Media Mandatory. In this post I focused on the importance of utilizing social media for risk management purposes - particularly reputation risk. Now is the time for bankers to create a plan that listens in on conversations specific to their bank as well as concerns overall. Bankers should assign a "community manager" to track activity. Additionally, this person should either act as the mouthpiece for the organization or run "traffic" by making sure that the right people respond to the issues in a prompt and honest manner.

In 2008, federal regulators and banking associations encouraged banks to create a crisis response program. This was part of the industry's effort to calm consumer fears regarding bank failures. While the requirements did not specify the use of social media, the use of social media as part of a crisis management/risk management program can assist in keeping adverse effects to a minimum and will allow banks to turn around a generally negative environment by being received as informed, honest and transparent. When using social media as a corporate communication channel banks must be aware of the nuances and expectations of consumers. This information can be obtained from my Community Banker's Guide to Social Network Marketing,which is a free download at http://www.tinyurl.com/cbgsnm. In addition, bankers should be aware of any other regulatory disclosure requirements to the extent that those are applicable (e.g., SEC rules, consumer disclosure rules, etc.).

Forewarned is forearmed.

Bank Lawyer's Social Media Checklist

On April 17th, I published Social Media and Bank Compliance Requirements, where I provided, thanks to the ABA Banking Journal, a list of regulatory compliance-related items that should be considered by banks that are thinking of or have already implemented some form of social media within their organization.

In this post I leverage (and paraphrase) off of the work of Richard Best as contained in NZLawyer article titled, "Social media and legal code: A checklist of issues."

Mr. Best highlighted four distinct areas that require legal consideration:

• Upfront governance and assessment;
• Site design and set-up;
• Content creation, moderation, and use; and,
• Content distribution.

Upfront Governance and Assessment

Questions that should be addressed :

1. Does the bank have a clear objective/rationale for creating a online presence with social media capability?
2. Has management and the board considered the business case for the development of a social media component? Is the presentation and board decision clearly documented in the board minutes?
3. Has bank management formed a steering committee with an appropriate mix of skills been set up to oversee the development and implementation of the site’s planning, policies, and procedures? At a minimum, members of this team should have a background in the nuances related to social media and Web 2.0.
4. Has a review and approval process been developed relative to the process? Who has the final say? Executive management? Board of Directors?
5. Has the bank developed the appropriate policies and procedures that address issues such as site usage policy, staff contribution guidelines, employee training (e.g., who is authorized) and ongoing assessment ?
6. Has the bank revised its record retention policy and procedures to ensure that electronic records created comply with applicable disclosure and security requirements?

Site Design and Set-Up

Questions that should be addressed :

1. Has the bank chosen and researched the availablity of the Web site name and domain name name?
2. Has the bank's Compliance or other Department completed a comprehensive risk assessment and have the results of the risk assessment been presented to executive management and the board of directors?
3. Has the bank determined whether the site be designed in-house or outsourced? If outsourced, has the bank completed an appropriate vendor assessment according to the bank's vendor management policy?

Content Creation, Moderation, and Use

Questions that should be addressed:

1. Has the bank's legal department developed a terms of use policy that complies with applicable laws, rules and regulations. Refer to Social Media, Banking and the Communications Decency Act post. Considerations should include:

• Registration obligations;
• Copyright and licensing disclosures;
• Warranties on the part of site users contributing third-party copyright content that they have the right to use such material;
• Indemnification of the bank against loss;
• Ownership or licensing of users’ contributions;
• Unacceptable use and the bank’s right to remove offending material;
• Cooperation with authorities in the event that material breaching other parties’ rights, or that is otherwise unlawful, is posted to the site;
• Moderation and banning of abusive commentators;
• Disclaimers of liability (to the extent appropriate), and
• Right to amend the terms of use.

Content Distribution

Questions that should be addressed:

1. If the bank will be resyndicating content from other sites on the bank’s site (e.g., through RSS feeds available on other sites), the bank should ensure that the bank is licensed to resyndicate that content.

Mr. Best does a great job of noting key issues that must be considered. While this list is not exhaustive, consideration of each point noted here will go a very long way in protecting the bank from a legal perspective.

I recommend that bankers download a copy of my Community Banker's Guide to Social Network Marketing to educate management and the board on what it takes to develop and implement a sound social media strategy. The Guide can be downloaded at http://www.tinyurl.com/cbgsnm. Before a bank can reasonably approve such a measure, decision makers must be knowledgable. The Guide goes a long way in providing an education on social media and social networks.

Social Media and Bank Compliance Requirements

The advantages of social media include the ability to better connect with customers, build the organization's reputation as being customer-focused and responsive, and set the organization apart from the competition. Many organizations have introduced social media components to their existing marketing strategy and more will follow in the near future as social media has surpassed everyone's expectations in terms of breadth of penetration and frequency.

Unfortunately, in their rush to implement such a strategy, some organizations may overlook the obvious...COMPLIANCE.

To assist bankers in ensuring ongoing regulatory compliance, the ABA Banking Journal released the following six social media compliance tips:

1. Conduct a social media risk assessment. Organizations should specifically identify the compliance requirements that apply to the proposed activity and evaluate the compliance risks associated with those requirements. Risks can originate from the statutory liability and regulatory penalties that are specified by law, or from reputational damage that could result from publicity of noncompliance (see the post on reputational risk as well as post on conducting social media risk assessments).
2. Establish policies and procedures. Organizations should establish written policies and procedures for the activity that clearly outline the details of offering and ongoing servicing. Every facet of the activity, from beginning to end, should be covered (see information on social media policies here.).
3. Establish controls to help address the risk identified in the compliance risk assessment. Controls may include a pre-publication review by compliance staff, assigning specific responsibility for specific functions associated with the activity, dual control, second review, and detailed checklists. One of the best controls is to include the compliance staff early in the planning process of the activity. The compliance staff can help build the process correctly from the beginning, rather than have to step in later to fix a compliance mess.
4. Set up a monitoring process. Establish an ongoing monitoring process to identify and correct errors before the examiners or the customers do.
5. Report to management. Management should be kept informed of compliance exceptions found through monitoring as well as regulatory developments affecting the activity.
6. Vendor management. Even if there are third party vendors involved in the activity, the bank should still follow its compliance management process. Risk assessment, policies and procedures, controls, ongoing monitoring, and management reporting are still applicable and just as important, because the bank is ultimately responsible.

Following these six tips should ensure that organizations remain compliant from beginning to end. Social media communications are no different from print, radio and television. As such, compliance officers need to ensure that they are in at the very beginning when talk of a social media strategy begins to emerge. Too often the Compliance Department is brought in after all the decisions are made and the money is spent. Getting a seat at the table where new initiatives are discussed will go a long way in preventing compliance related fiascos.