by Jimmy Marks
Recently I attended the CU Symposium in St. Michaels, MD and saw a presentation by COMPASS 4 CUs, a compliance CUSO dedicated to useful, easy-to-understand compliance help. I learned a lot, seeing as I’m not a “compliance person”, and I know most people think about the message first and the compliance language last. It’s almost a curse – you’d think someone was coming in and putting censor bars all over everything. But compliance is important and it’s always on the minds of the folks I talk to, whether they’re bank folks, credit union folks, or social media folks.
[Now, before I go any further, I have to be "compliant" and state the following: none of what I'm about to say should be taken as LEGAL advice. ALWAYS consult with your organization's compliance person, and if your organization doesn't have one, consider retaining a professional.]
Okay, now that we have that out of the way, let’s talk about what your credit union shouldn’t say on social media, according to the “Compliance Queens” at COMPASS 4 CUs.
1) “Get Pre-approved Today!” — This is a big no-no. You can’t pre-approve everyone. It’s not possible. Some folks aren’t going to have the credit rating for that. Better Bet: “See if you qualify for pre-approval today!”
2) “We’ll beat the competition!” — No, you won’t. Not if you leave the definition of “competition” so open-ended. Better Bet: “Come see how we stack up to other FIs in the [wherever you are] area!” You’ve got a little wiggle-room in there.
3) “Get an auto loan at 1.99%” — Don’t discuss rates in specific terms. Not everyone can qualify for your best loan rate. Can you promise a great interest rate and low down payment to someone with horrible credit? No. You can’t. Better Bet: “Auto Loans at 1.99% — qualifying borrowers only, see site for details: [link to site]”
4) “Anyone can join!” — Doubt it. Get specific about what qualifies your field of membership. Better Bet: Get specific. Very specific. End of story.
5) “We can save you money!” — Can you? One of the common themes you might have noticed in all of these is that they’re all too general about who can qualify for what and what you can do for any person in your social media audience. Better Bet: Talk about what members could save “on average”.
It’s not deceptive to say someone could save money, that they could get a better loan rate. It’s deceptive to say they WILL. Promises made and not kept are dangerous. Stay away from them.
Now, I know what you’re thinking: these seem similar to the restrictions placed on our print and online advertising. That’s because social media is regarded as a branch of marketing. Whether you want to call it “community building” or “e-commerce whizbang whatever”, it’s marketing. Your hands are bound by those restrictions. Some other good best practices:
- Always have your NCUA logo/Equal Housing logo ONE CLICK AWAY from your social media posts. That is, if you’re going to put a link on Twitter about your mortgage services, the next page a person reaches should have all the legal language required and the logos somewhere on the page.
- It never hurts to disclose that you’re linking to a third-party website, even if you’re linking from Facebook/Twitter/etc. to another external site.
- Remember that no social media sites are built around what banks/credit unions need – they were built for sharing short, simple messages, links, videos and pictures. You’re never going to be able to cram everything you need into a single post, so don’t try. Make sure you have good landing pages with actionable content, paths you can trace from site to site to measure your SM performance, and always – ALWAYS – the most current compliance language and related logos and images.