Is Your Social Media Compliant?
Be sure to JOIN US for our Advertising webinar.
We get a lot of questions regarding the advertising requirements for social media…both for deposit products and loan products. Many people believe there are exemptions from the advertising disclosure requirements, which simply is not true. Internet/social media advertisements are to be treated the same as newspaper advertisements, in most cases. This webinar will cover the requirements for deposit and loan product advertising such as FDIC signage, Fair Housing rules, bonuses and much, much more.
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There are no exemptions for social media when it comes to the internet.
Hi, it’s Dave Dickinson with bankers compliance consulting. I want to talk to you about advertising and specifically about social media advertising. We get a lot of questions where loan officers are saying, I can’t get all of the disclosures that I know that the regulations require. So there’s gotta be some exemptions for things like Twitter because of the limited fields where I can’t get a fair housing logo on my Facebook page, but I want to be able to promote those home loans. And I’m sorry, there are no exemptions for social media when it comes to the internet. See it as a newspaper advertisement. Yes. When it comes to loan advertisements, there are some exemptions from some of the disclosures for TV and radio, but not other types of electronic media like the internet. So a long time ago there was some rules put out that said we don’t care and how you’re advertising it, but you have to give all the disclosures even if it’s on the internet
Now, there is one thing that was written back several years ago that allowed us a little way to gloop hold this and it’s called the one click away rule. That’s our plain English way of saying it, but if I can have a click here for more information type of link and that link takes us to a website where we’re taking directly to, that’s the keyword directly to the disclosures. Then you don’t have to have the disclosures on there. So on Twitter for instance, on your Facebook pages, things like that. You could say something that might trigger more information, but say click here for more information. Now the catch directly to it’s not, I go to your homepage and then I have to go to another page and scroll down. It’s not even I go to the page and have to scroll down. It is directly to the disclosures and if you’re doing that, then you don’t have to have all the disclosures on that electronic advertisement like Twitter, Instagram, Facebook, et cetera.
Published
2021/02/02
David Dickinson
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.