Social Media Marketing Regulations

Transcription

1 Annual Convention and Exposition Social Media Marketing Regulations May 16, :15 2:15 p.m. Facilitated by Jonathan Fuhrman Sponsored by Facebook Federal Financial Institutions Examination Council (FFIEC) State of Michigan Lotto Laws Lending Laws and Advertising 1

2 Can t be deceptive, misleading, or infringe on anyone else s copyright iht May not encourage people to upload your cover to their personal timelines Can t have more than 20% text cover com/facebooimage guide/ cover 2

3 Must be administered within an application Must tinclude: Complete release of Facebook by each entrant or participant Acknowledgement that the promotion is in no way sponsored, endorsed or administered by or associated with Facebook Disclosure that the participant is providing information to your credit union and not to Facebook Can t condition registration or entry upon the user taking any action using any Facebook feature or functionality other than liking a page, checking into a place or connecting to your app Can t use this as the only registration or voting mechanism Can t condition registration or entry upon the user liking a wall post, commenting on or uploading a photograph on a wall 3

4 Must not notify winners through Facebook Direct messages Chat Posts on your profile Post to their profile Post oncontest app 4

5 Social Media: Consumer Compliance Risk Management tguidance published on January 17, 2013 Concern over management of risk profile Defines social media and provides guidance to help identify, manage and address these risks Social media strategy Formal social media policies and procedures Management of third party vendors Employee training program Monitoring of social media channels Audit and compliance functions Reporting of return on investment 5

6 Sets goals and objectives Defines target audiences Identifies the most effective social media platforms Develops a strategy and tactics to reach target audience and achieve objectives Etblih Establishes and update, dt monitoring i and response process Sets measurement metrics Follow consumer protection laws, regulations and guidance Manage the risks associated with postings and replies Careful when posting (i.e. don t make firm offers) Managing negative comments 6

7 Establishing a process for vendor selection Protecting your consumers (followers) when other parties are involved Making sure all employees who use social media on behalf bhlfof your credit union understand all internal policies and procedures along with all state and federal laws and regulations Educate all employees on their use of personal social media profiles 7

8 What is being said on your page as well as other pages Google Alerts Twitter Alerts Can be internal or external Ensure compliance with internal and external regulations Times change you have to as well! 8

9 Facebook Insights Google Analytics Track all networks with established data points Report this information in your quarterly/annual marketing efforts 9

10 Contest: A giveaway that has an element of skill Best photo, video, recipe, etc. Sweepstakes: Enter your name and provide contact information Think HGTV dream home Consideration Legal Lottery Chance Prizes 10

11 Buh bye consideration Don t pay to enter Purchasing a product will not improve odds Don t have to do anything that financially benefits the company running the contest or sweepstakes No purchase necessary to enter or win Open to residents of the United States and District of Columbia age X and older Mail in entry option Entry period Official rules URL 11

12 Are you talking about real estate and mortgages? Fair Housing Logo Are you talking about deposit products? NCUA logo 12

13 6 hours and 35 minutes each month Can be utilized to engage people in a conversation, not just advertise to them Great analytical tools provide insights for clicks, actions and return on investment Easily able to segment and target more than any other medium Location city or zip code, can include surrounding radius Age and Gender Interests Education Workplace Relationship status Precise Interests cooking, gardening, cars, home remodeling, even specific pages 13

14 I m going to target my mortgage campaign at females, ages 28 34, who live within 10 miles of my branch, have a college degree, and became engaged in the last 6 months. Engaged women are more likely to be house shopping, and a college degree means they are more likely able to afford a house. 14

15 Overt a lender blatantly discriminates on a prohibited basis (not lending to women) Disparate Treatment Lender treats applicants differently based on one of the prohibited factors (husband must cosign on a woman s loan) Disparate Impact Lender applies a practice uniformly to all applicants but the practice has a discriminatory effect on a prohibited class (target women who have college degrees) Race or color National origin Religion Sex Familial Status (children under 18 living in household) Disability 15

16 Make sure all your employees who use social media on behalf of your credit union understand all advertising laws that financial institutions must follow Don t assume the third party vendor you are working with knows the laws as they apply to financial institutions Have fun with social media, but remain compliant Annual Convention and Exposition Jonathan Fuhrman Marketing Consultant CU Solutions Group jonathan.fuhrman@cusolutionsgroup.com ext