Before we get started, let’s define digital media. It includes digital display ads, search engine marketing, social media, websites, email marketing, etc.
As bank and credit union marketers, you need to keep the following points in mind as you are creating your digital promotional components:
1. Don’t be misleading. For example, if your bank or credit union promotes a checking account that requires direct deposit and a specific number of debit card transactions each month before they qualify for the account benefits, your headline/body copy should not imply they will always receive these benefits. Include something like “when you meet qualifications” so the consumer knows there are requirements. Then provide or link to the details.
TIP: Your headline/body copy should not conflict with your disclosure.
2. Don’t discriminate. This is true whether you are working on a traditional or digital campaign! Discuss your target audience with your compliance team (and your digital provider, if applicable) to avoid discrimination. There are many tools available to help target specific groups more than ever before. However, that can also lead to unintentional discrimination. Here are a few things to keep in mind …
- If you are promoting a special offer on a product that is applicable to all groups in your bank or credit union’s assessment area, be very careful not to exclude certain geographies within your footprint or discriminate based on “prohibited basis” (such as race, religion, national origin, gender, marital status, age, use of income from public assistance programs, familial status, handicap, or leave out low- and moderate-income households).
- However, there are times where you can limit the target audience for your campaign. A couple that come to mind are: if you have a senior’s club account or you are opening a new branch location and need to focus on the area surrounding the branch to help it grow. Always make sure you have a good business purpose that you can document and justify showing you are not discriminating.
TIP: Think about the product you are promoting – is this a universal product for everyone OR is there specific criteria to be eligible?
3. Use one-click away correctly for digital advertising. If you need to link to more detail/disclosure, clearly direct them to the link (button, phrase, URL) and then link them directly to that information.
TIP: Link directly to the details they need, don’t make them hunt for it!
4. Include Official Statement for Member FDIC or NCUA in your Search Engine Marketing (SEM) ads for deposit products. Even though you have very limited characters available to you, we recommend including Member FDIC or Federally insured by NCUA within your character count.
TIP: Many compliance experts say that one-click away is not sufficient for the official advertising statement for FDIC or NCUA.
5. Keep your website up to date. I’ve seen many bank and credit union websites where it’s very obvious their information hasn’t been updated. In some cases, their promotional materials even conflict with their website.
TIP: Out-of-date websites can cause confusion about product features AND they don’t help to attract new customers/members!
6. Get your compliance team’s approval for all advertising. Even though digital ads have very little copy, they still need to be approved from your compliance team just like your printed materials.
TIP: Even a headline can make a false claim, be misleading, or trigger additional disclosure.
7. Don’t purchase email lists for your campaigns. That’s right, I said banks and credit unions should not purchase email lists! Here are just a few of the reasons that come to mind:
- Most email service providers do not allow you to purchase lists and upload to their system
- Your financial institution could be identified as a spammer
- Persons on the list may have already opted out from receiving your emails
- Some lists are compiled illegally via address harvesting, dictionary attacks, etc.
- Emails work best when they are sent to your customers/members or those who have indicated an interest in receiving messages from your financial institution
- Sending unsolicited emails to a purchased or rented list can affect your response rate and damage your IP reputation
TIP: Once again … Don’t purchase email lists!
8. Archive your digital advertising for your examiners to review during your exam. There are many automated tools to archive your digital ads/posts with searchable content. In some cases, bank and credit union marketers do this manually.
TIP: Regardless how you do it, you need to provide an archive of your digital advertising (along with your print advertising) when an examiner asks for it.
The purpose of this blog is to provide general marketing compliance information to assist you and your compliance department. It is not intended, nor should it be used, as a substitute for consultation with your compliance officer or legal advisor.
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