Is your marketing compliant? Do you know what you can and can't say? What about your social media posts? Are they compliant? These are big questions and they won't be ignored. The compliance authorities are bringing their A game, and so should you! Catching one examiner's eye could end up costing you thousands if your marketing efforts breach certain parameters, and it doesn't even require them to visit you onsite. Let's take a closer look. It all begins with basic guidelines set forth by the CFPB.
Basic Marketing Guidelines
The guidelines were established by the bureau as an effort to protect consumer interests. Here are general guidelines to follow when advertising on print, television and radio. All marketing and advertising efforts must: Be factual and accurately represented, clearly explain the product or service being offered, give no misrepresentation of cost or terms, make sure all disclosures are prominently displayed and avoid using unfamiliar terms.
Keep in mind these are general guidelines. Essentially, the idea behind the guidelines is to make sure you communicate your message clearly and to describe the product or service being offered in an accurate, honest manner. This allows the consumer to make the best possible decisions regarding the product or service being offered.
Social Media Best Practices
Social media is a different animal entirely. The platforms are expressly designed for consumer engagement and they encourage advertising. However, you still need to know what you can and can't say. Here are some online best practices to consider:
Be consistent. The biggest challenge is making sure your message and offers on social media match those offered elsewhere. Consistency is paramount for compliance. This includes whom you are targeting your message to as well. Just as you cannot discourage when targeting members in a mailer, the same is true for your message on social media.
Be careful when sharing other content. If you share content posted by another source, you could inadvertently fall under their compliance guidelines. It is always best to treat third-party content just like you would your own content. Check with your legal department to make sure you are not putting your credit union at risk.
Watch the details. On social media, brevity is king. However, it may not be the best rule of thumb to use for advertising. For example, if you are holding a contest, using the words "enter to win" is not the best choice. The implication is anyone who enters will win. A better term might be "enter for a chance to win." It's a bit longer, but compliant.
Invite rather than advertise. A great way to maintain compliance on social media is by extending an invitation. Simply post an invitation to check out a product or service your credit union is offering, then link to the corresponding page on your website. A line such as, "Thinking of an automobile loan? Click the link for more information." is a great lead-in line that invites the consumer to discover more about your product or service.
These guidelines are not much different than guidelines used for other forms of marketing, but they are important to keep in mind with social media as there is always a push for fantastic content and brevity.
Finally, When Can You Use the Word FREE?
It is quite common to use the word FREE to attract consumers, but is it safe? Absolutely … as long as you clearly define the context immediately following the word itself. This is a guideline used by the FCC that is very helpful in all marketing respects for credit union advertising. You can say things like "Free loan consultation" or "free checking for X" (clearly state the audience and parameters). Again, run this by your legal department to be safe since all offers are targeted to different audiences, and may have different compliance requirements.
Richard Gallagher is the CEO of Oak Tree Business Systems, Inc. He can be reached at 800-537-9598 or [email protected].
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