FFIEC Guidance and Customer Outreach

How Bank of the West Approaches Fraud Awareness
FFIEC Guidance and Customer Outreach

New and proposed regulatory guidance for online fraud prevention and social media spurred Bank of the West to enhance customer outreach and improve fraud and risk awareness.

This San Francisco-based institution has launched a new series of videos featuring a handful of the bank's top thought-leaders to spread the word about financial fraud prevention and security. The videos address customer education and awareness, priorities mandated by the Federal Financial institutions Examination Council in its updated authentication guidance as well as its proposed social media guidance.

"The [FFIEC's Internet banking guidance] specifically says there are certain minimum requirements," customer education being one of them, says David Pollino, who heads fraud prevention for Bank of the West, during an interview with Information Security Media Group [transcript below].

Pollino, along with Joel Nathanson, who oversees social media for Bank of the West, says the new video series, available on YouTube, is focused on providing detailed information about fraud scams, especially in areas related to account takeover, identity theft, and elder and small-business fraud.

The bank says regular reviews of the series' effectiveness will be key, however, to ensure the program remains relevant and up-to-date. "Measuring things such as clicks, engagement, banner ads, those types of things," Pollino says.

During this interview, Pollino and Nathanson discuss:

  • How Bank of the West's program is ensuring conformance with FFIEC guidelines;
  • Why social media plays a critical role in customer education;
  • How other banks can spearhead similar campaigns.

Pollino is Bank of the West's senior vice president and fraud prevention officer. At the bank, he focuses on information security and combating online fraud linked to cybercrime. Before joining Bank of the West, Pollino served as manager of online fraud prevention strategy and analytics for Wells Fargo and was the online risk officer for WaMu.com. Pollino also managed online risk and information security investigations at Charles Schwab.

Nathanson is Bank of the West's senior vice president and head of social media. With more than 17 years of business and finance experience, Nathanson has emerged as a leader of social media strategy and the customer experience. He has developed and executed social media programs for Wells Fargo, Charles Schwab and Bank of the West. Since joining Bank of the West in 2010, Nathanson has developed a comprehensive social media strategy and overseen the launch of the bank's Facebook, YouTube, Twitter and LinkedIn channels.

Bank of the West

TRACY KITTEN: Tell our audience a bit about the role each of you plays at Bank of the West.

JOEL NATHANSON: Bank of the West is headquartered in San Francisco, and it's part of the BNP Paribas Group. We've got a strong presence in the Western U.S., and we're known as a trusted adviser for more than a million and a half consumer and commercial customers. We actually just ranked second in the U.S. for reputation among 30 of the largest commercial banks in 2012; so we pride ourselves on serving our customers and the public. It's that reputation that actually attracted me to Bank of the West in 2010. I have 17 years of experience in business and finance, with the past eight years focused specifically on social media and banking. So as head of social media, I've developed and currently manage a comprehensive social media strategy, including the launch of the bank's Facebook, YouTube, Twitter and LinkedIn channels.

DAVID POLLINO: I'm the fraud prevention officer here at Bank of the West. I, too, was attracted to Bank of the West by the solid reputation that it had in the industry. I have about ten years of fraud prevention experience and another five years before that doing information security. I thought my experience was a great fit for being able to come and start the fraud prevention function here at Bank of the West, and educating customers is part of that role. We found that smart customers make good decisions.

Enhancing Customer Education

KITTEN: Joel, your role as senior vice president and head of the social media department for the bank brings some different perspective. How is your department working with the fraud department to enhance customer education?

NATHANSON: We do live seminars and outreach to print and traditional media. But as we all know, more and more people are looking for information on YouTube, Facebook, LinkedIn and other social channels. David and I partner on getting that content out to help raise awareness and understanding of the issues in order to help keep our customers safe.

Educational Videos

KITTEN: Bank of the West has recently launched a series of educational videos that are aimed at a variety of topics, including e-mail scams and elder abuse fraud, as well as online job scams. What can you tell us about these videos and how are they being promoted?

NATHANSON: The fraud videos are part of an expert series called "In Brief" and include business leaders from across the bank who are sharing actionable information with the goals of educating consumers and helping them make better financial decisions. We just launched these videos on our YouTube channel in March, and we're pretty pleased with the views so far. We'll continue promoting them through a variety of channels, both social and traditional, in the future.

As we saw recently with our video series on mortgage, we expect over time that they'll attract an increasingly larger number of views and serve as an ongoing educational resource for a really broad audience. All the videos are available on www.youtube.com/bankofthewest, as well as within the Bank of the West online fraud center, which also contains detailed information about fraud scams; personal, elder and small-business fraud; as well as security tips for consumers and commercial entities.

KITTEN: How did you decide which specific points to raise and the types of fraud education pieces to include?

POLLINO: We view our security and fraud centers as our ongoing dialogue with our customers. We revamped the online fraud center in June of 2012 with all new content, leveraging the subject matter expertise from around the bank on a variety of topics. We try to make sure that all the content that we have in our fraud center, as well as the topics we choose for the "Fraud in Brief" videos, is related to current issues our customers ask about. e.

KITTEN: Are other social media venues beyond YouTube being used as well?

NATHANSON: To be viral, the content must be widely shared. The content must be both relevant and compelling. Online fraud is a topic that changes often and everyone can identify with. With experts like David at Bank of the West, we can play an important role in getting that information out to keep our customers safe.

FFIEC Social Media Guidance

KITTEN: Have the FFIEC's proposed guidelines for social media affected Bank of the West's program strategy?

NATHANSON: The proposed guidance by the FFIEC is just that. It's guidance; not regulation. And honestly, I've been expecting it for years. Social media has evolved so quickly that I think it's great to bring some structure and best practices to the industry. It's really to everyone's benefit. Bank of the West is already well positioned to adopt these guidelines.

Social Media's Role

KITTEN: Would you say that Bank of the West views social media as being more of a benefit than a security hindrance?

POLLINO: We do know that our customers are on social media and it's here to stay. They share a lot of information about themselves on social media, which can be used by criminals. We do caution everybody to be very careful about the information they choose to put online about themselves. This can be used by criminals in various different ways, such as for identity theft and those types of things. By making our content available, hopefully that will enable our customers to make good decisions about what they're sharing online.

KITTEN: Has the bank noted decreases in fraud losses since the launch of this program and the subsequent video campaign?

POLLINO: Protecting our customers is the top concern here at Bank of the West, and that's why we've invested so much in our security and fraud content. We hope it's beneficial, not only to our customers, but also other people [who] will take advantage of it to protect themselves. As far as trying to measure the effectiveness of the program, since we're still in the early phases, it will take a little bit more time for us to evaluate the program's effectiveness.

Judging Success of Awareness Program

KITTEN: What measures does the bank have in place to judge the success of this program in the future?

POLLINO: We do watch how many visits we get to our security and fraud centers. We also try to promote the program through onsite advertising and social media. And during Cyber Security Awareness Month, we try to heavily promote the content that we have there. We really try to make sure it doesn't get stale and that it's addressing customers' needs. Since our last revamp of the site in June of 2012, we've had a couple of additional content releases about current scams that are going on.

Customer Feedback

KITTEN: What types of questions are you getting from retail and commercial customers about the scams that they're seeing?

NATHANSON: On social channels, there are some customers who have very specific financial questions. But most really want to interact with us around other common interests, like community, nonprofit programs, contests and sweepstakes.

KITTEN: What about you, David?

POLLINO: Our customers want information available online. When they do have a question, they want to be able to reference that information, read it and potentially share it with other people. Having good, rich content available online also ensure everybody internally knows how to direct customers to information that is important.

Getting the Word Out

KITTEN: David, you also host on-site forums or meetings to educate customers about fraud. What other efforts has the bank spearheaded to help get the word out?

POLLINO: Aside from our security and fraud center, during the holiday shopping season we promoted an event with the U.S. Secret Service to talk about counterfeiting. We've had seminars around elder abuse and other events that are targeted at our business and commercial customers. As we've said before, we really view this as a partnership with our customers. The more interactions we can have with them, the stronger the relationship.

Top Threats to Customers

KITTEN: One of the areas that I found quite interesting in the videos relates to e-mail scams and phishing schemes. Where are customers falling victim most often?

POLLINO: One of the things that we're most concerned about is organized online crime. We know that the crime has moved online and now they're utilizing tools such as malware and phishing, are taking over e-mail accounts, and all those things are used to commit fraud, either against the bank or against our customers. In many cases, our customers may have met people online as well that they fall victim to, and so those are areas that we're most concerned about.

New Program Offerings

KITTEN: What about new program offerings you anticipate for the future?

NATHANSON: From a social perspective, we'll be expanding on content from our experts and providing valuable information to our audiences. Integrating Facebook, Twitter, YouTube and LinkedIn channels, along with blogs and mobile-focused apps, [is] going to keep us pretty busy this year.

POLLINO: We're also going to be investing in our online infrastructure - the tools we make available to our customers, our authentication tools that we have available on our different Web properties, as well as malware protection from McAfee and Trusteer available on our website, which are all tools our customers can take advantage of.

Advice to Institutions

KITTEN: What advice could you offer to other banking institutions interested in offering similar programs and services?

NATHANSON: Social media moves fast, so be thoughtful. Have a clear strategy before launching a new channel. Just because you can doesn't mean you should. Remember that quality over quantity is the winning formula.

POLLINO: To really promote that quality, leverage your internal subject matter expertise and knowledge. If you ask around, you'll probably find a number of knowledgeable individuals in-house who can help you create the content that's most top-of-mind for customers today. Make sure that you not only promote it externally but you also promote it internally, so that everybody at the institution knows it's available.

Considerations for Fraud Prevention Programs

KITTEN: Are there any areas, such as those outlined by the FFIEC in its authentication and social media guidelines, that banking institutions have to consider?

POLLINO: There are a couple of things that are mentioned specifically in the FFIEC Internet banking guidance. It specifically says that there are certain minimum requirements, from a content perspective, so you should make sure that you're meeting those minimum requirements. In addition to that, there needs to be a regular review of the effectiveness of the program. Measuring things such as clicks, engagement, banner ads and those types of things can be accomplished on an ongoing basis and reported to management. To make it most beneficial, not only to the institution but also to your customers, make sure it stays up-to-date with the current trends and issues that you're seeing; and don't be afraid to update it frequently.

NATHANSON: Many of the current regulations affecting social media focus on transparency - having clear terms and conditions, appropriate disclosures and ensuring promotions are not misleading in any way. I'll also add community management and content monitoring as the best practices and an all-important considerations for these programs.


About the Author

Tracy Kitten

Tracy Kitten

Director of Global Events Content and Executive Editor, BankInfoSecurity & CUInfoSecurity

Kitten was director of global events content and an executive editor at ISMG. A veteran journalist with more than 20 years' experience, she covered the financial sector for 10+ years. Before joining Information Security Media Group in 2010, she covered the financial self-service industry as the senior editor of ATMmarketplace, part of Networld Media. Kitten has been a regular speaker at domestic and international conferences, and was the keynote at ATMIA's U.S. and Canadian conferences in 2009. She has been quoted by CNN.com, ABC News, Bankrate.com and MSN Money.




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