How to Stay Compliant on Social - Social Assurance
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How to Stay Compliant on Social

May 22, 2019
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What We Already Know

  • Working together is essential. It’s important to know who will be involved, what the project goals are and who is assigned a role in writing, designing and approving content.
  • Consider the project and timeline to clarify expectations and deadlines. Plan for the unexpected and make priorities to prevent any last minute decisions.
  • Avoid decision fatigue by determining which posts your compliance team needs to approve.


What We Need to Know

  • Your post shouldn’t take users on a chase to give them the information you promised. Terms and conditions should be available within one click.
  • Banks are limited by a variety of different regulations in their online advertising depending on the product.
  • In general, the compliance process is the same across social platforms., so your processes should also be the same.


What’s Changing

  • Rules, regulations and best practices are constantly changing! Stay updated by continuing your education on social media developments (e.g., Social Assurance blogs, webinars, etc.)
  • Develop responses for the new ways your customers are communicating — like messenger.

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Ben Pankonin 0:14
Welcome today, we are getting ready to kick off another webinar. And I see many people are still joining just now. But welcome. This is an exciting webinar for us. We’re talking about being compliant on social. And we had a lot of questions before the webinar. I’m really excited. It looks like people are enthusiastic to talk about what’s what’s compliant, what’s not, how can we kind of think through a lot of the strategies we have. And there’s just a lot to cover here. So I’m excited today, I’m joined with Alexander law argue for those of you who have joined with our webinars before you know, my voice. I’m Ben painting in the founder and CEO of social insurance, and we’ve been doing compliance social media for a long time now. actually went back to the original blog that I wrote the first night that the F of IEC guidance came out. It’s still published on our on our website. Oh, wow, I kind of pulled an all nighter that night. And I was like, Hey, this is this is this is our jam. Yeah. And it was, it was really kind of funny to see it. I need to rewrite it. Sir, like, after all these years, like there’s a lot that we have to add to it. And so stay tuned, I probably will do that. When I get a chance. I probably won’t pull an all nighter for it. But yeah, but we’ll we’ll get some updates to that. Because I really think there is a lot to consider in all these years since that.

Alexander Lahargoue 1:36
Oh, yeah. I mean, there’s been so many updates and changes to it. But I mean, must been a fun walk down memory lane, though. For you to see it. Yeah,

Ben Pankonin 1:41
yeah. No, it was good. And and we were just talking about some of the different things going on. And, you know, when we think about it, a lot of the things that were written there was just about five years ago now. Really, it’s not that the guidance has changed, but we’ve had so many changes to social media in that time. And I think the way We approach that think about it as something that we have to continue to stay on top of. So, you know, if you’ve been out to the, to those compliance webinars could have even been one of ours years ago, we probably weren’t talking about the same things that we would talk about now. That’s so true. Yeah. So I think that’s, that provides a good backdrop for us to have some discussion. A few points to take away. If you’re hanging out on Twitter, tweet with us. Hashtag social bank. Also, we were glad to answer any questions in the webinar itself. Alexander is really helping manage a lot of those questions. So if you got questions over on the right side, for many of you, some of you may have it at the top, a little control panel, you can hit the chat and have a quick conversation, send out some of those chat conversations. I’m guessing that you’re gonna have a lot of questions on this one, some of which we’ll be able to get to. If we don’t get to it. You can always email me, you can always tweet to us. We are glad to to try to jump into some of those and often we do have Some of those just at random times where people say, hey, I’ve got this weird random question. So anyway, feel free to jump in with us today. But also, I wanted to reflect for a quick moment. This is leading up to Memorial Day weekend. Memorial Day is coming up next Monday. For those of you who don’t have your posts scheduled out for social media, there’s a quick reminder for you there. But also, I think it provides a great reflection Alexander and I were talking a little bit earlier, you know, I my dad served my grandpa’s served. They, you know, had a lot of friends who they lost. And so I think that’s really something that we want to reflect on. And, and I know you mentioned that your grandfather served in the Air Force as well. That’s true. Yeah. Yeah. And, and, you know, so we’ve known a lot of people who have served and and i think that sacrifice is something we want to be very cognizant of. And when I was prepping this webinar, a lot of that was stuff that I was reflecting on. Really kind of ended up into kind of the the schedule and how we’re how we’re talking about how do we approach compliance? How do we approach the different aspects of social media. And so we’re really breaking it up into the domains of military tactics historically, which is, which is kind of an interesting way to think about it, because we don’t often think about those domains. But when we think about the historic tactics that were used, we had different tactics for land, as for air as for sea, and I think that provides us a backdrop when we think about how we’re approaching social media. So we’re going to tackle those in a rather interesting way when we think about the tactics for land. That’s really the historic way that that battles were fought, and really, it’s about what we already know. So when we think about how we’re engaging in our social media, the the land tactic is What we already know it’s a landscape. It’s where we come from. So when we think about working on land, we think about how are we organizing all of our projects together? Who’s going to be involved? So most of you have a social media committee. You’ve organized that that’s been established. But you know, we want to figure out how those goals work together, and how you’re managing those social media committee meetings. If you’re struggling with those social media committee meetings, reach out to me I’ve got a little takeaway. In fact, I’ll put it in the in the notes after the webinar, for just some ways to organize those social media committee meetings, because I think a lot of times we end up focusing heavily on the, you know, one negative post we had over the previous month or quarter. And, you know, when we can focus and say, Hey, here’s how we’re dealing with that compliance. When we get into that overview and oversight Really what we’re thinking about is, what worked, what didn’t work? Did we maintain a good risk management strategy when these things came in. And a good risk management strategy says that we should be active, we should be quick to respond, we should be checking the boxes we need to check. And so those are the types of things we want to think about in those compliance meetings. And so, you know, we want to make sure that that’s really the prevalent strategy there. Now, we also want to consider, you know, how, how we’re maintaining a timeline. So you know, making sure that we’re planning everything we can, and that our, our efforts are all sustainable. You know, over the course of these last years, as you know, from the fmic guidance coming out to now, we’ve witnessed a number of financial institutions who have started out strong, and they’ve had a calendar or process that wasn’t very sustainable. And so you know, we want to make sure That it is a sustainable process. So if you’re developing a content calendar and you say, hey, I want to make sure I have a Facebook post going out every day, I want to have, you know, one to five tweets going out every day. Is that a sustainable process? That’s something you really want to evaluate and reevaluate. If you’ve seen some drop off,

Alexander Lahargoue 7:20
yeah, I think that’s a great point. Because unless it’s sustainable, it’s not something that you continue doing in the future. We did get a question from Kayla, about what are some common pitfalls that you see financial brands, when they try to tackle those sustainable efforts? What makes those not sustainable? Really?

Ben Pankonin 7:35
Yeah, that’s a great question, Caleb, you know, I think one of them is that they, they think that content just comes from anywhere, and that it’s easy to find the right content. It takes a lot of time. So if you’re doing that in house and you’re writing all of your content, you know that it takes a lot of time and sourcing that content is tough. We’re going to be talking about some of the compliance pitfalls here as well which are You know, when we try to tackle too much and have have everything really we overburden our compliance department, and we’re going to try to talk through some tactics of how to to help lighten the load there. I think that’s the other thing we’ve seen is that oftentimes we get we get overworked in that area, and there’s so much more that’s getting piled on to compliance. And we just have sort of continued piling it there, and we haven’t taken anything away. And so I think that’s really an area we’d like to touch on. There’s so many more messages that we have from an advertising review perspective than we had just two years ago. Yeah, for most of you. And so I think that’s really an area that we want to we want to try to eliminate as much as that as we can. So one of those is in this area of decision fatigue. And so it’s thinking about how much content we have and how do we take some of the That load off of our compliance officers. And so what we’ve seen a trend towards is when you’re reviewing content, figuring out what you want to review, that, that has different compliance needs to it, and some that don’t have as many compliance demands. So that might be, you know, for some of you that are saying, hey, when I go out and take a photo at a golf outing that has our logo in it, there’s, there’s, that’s a pretty low compliance risk. I shouldn’t have the same level of effort reviewing that post as I do, one that might have respa Tila, all of those sorts of regulations attached to it, because it contains a lending product. So when we can make a distinction between what is product post related, what is not product post related, and we can make a distinction there we can start to lighten some of those loads from our compliance staff and maybe some of those posts can be reviewed simply by our marketing staff. And then those ones that contain phrases like APR, we can say, hey, that’s something that we clearly need to have reviewed, would you? Would you recommend that our listeners incorporate that streamline review process in through actual procedures? Yeah. So I think it’s something that you want to document. It’s something you want to review as a committee so that you understand what’s coming in what would be the real risks here associated with that. But we’ve noticed a trend towards that to speed up that process, but also to help reduce that, you know, decision fatigue, because we’ve got, you know, compliance staff is reviewing so much so much content, that it’s great to, to be able to separate out and share that load a little bit. That also then for some of you means educating other people within your organization, and that has a trickle down effect because we have to educate a little bit more. But that’s the The other way we might help with that decision fatigue is saying, hey, when you’ve got something that you want me to really review, and highlight, then mention that to me, let me know that this is of higher priority. So, so we’ve seen a number of trends within our software application where we’ll see, maybe people fill out a checklist when they’ve got that product related post. And they might put that in their notes, they might add that checklist. But then, you know, when they’ve got that, you know, again, golf outing post, or, hey, we awarded someone a scholarship. Maybe we can lighten that a little bit, and just make sure that, you know, everything should be okay on this one, but I just want your final approval, right? So there’s a lot of ways you can structure that. So for some of you that might be even reaching out to some of our support staff, if you’re using our, our product and saying, Hey, we want to, you know, think about how we might streamline that. There’s definitely a lot of tactics we’ve used to do that. That’s something we’re We’re always up for, you know, kind of retraining or re revamping some of that and, and even looking at the policies, like you said, you might have to take a look at that, too. So Additionally, you know, when we look at decision fatigue, if we really think about decision fatigue, you know, what happens there is that, and there’s been some great tech leaders who have talked about their decision fatigue, Mark Zuckerberg and Steve Jobs are two that that come to mind that have literally said we were the same thing every day, because that’s one less decision.

Alexander Lahargoue 12:35
Right? Yeah.

Ben Pankonin 12:36
I think it’s, you know, they sort of taken this to an extreme and organize their life in a way to say, we have so many decisions to make in life. How do we take you know, one or two away from that? Every day that adds up to a lot more mental capacity to make other what they deem as more important decisions.

Alexander Lahargoue 12:55
I don’t know for me, you know, it was important what I what I put on today.

Ben Pankonin 13:01
But you know, when you think about that, and you think about the amount of posts and things we’re pushing through to compliance staff, the way that we separate out those posts and grant priority really helps that decision making process to go faster. And also, we talked in the beginning a little bit about creating a calendar and flow when we create content beforehand and schedule what we can, that allows a workflow to exist, that doesn’t make everything an immediate priority. So when we can prioritize that and say much of this content, we’re scheduling out a month in advance, or several weeks in advance that way this Friday at four o’clock is probably not the time to review the flag related posts for Memorial Day coming up on Monday. It’s probably that’s probably something we could schedule that far in advance. We know when it is we know when those types of activities and posts are going to happen. We Don’t have to have those be urgent.

Alexander Lahargoue 14:01
Right? It sounds like keeping decision fatigue Top of Mind is one of the keys to making sure that our efforts and creating content are sustainable?

Ben Pankonin 14:10
I think so I think it just helps smooth out that review process. Now for many of you that are starting to get more loan officers involved, that ramps things up to another level as well. And you start to think about how are we helping reduce that load, if we’ve got that much more content, whether that’s using keywords to help do that, whether that’s filtering and managing pre approved content, we have a number of ways that we can kind of help do that. But there’s a number of ways that we can think about that. Another known quantity when we think we’re still in this land phase of understanding what what on land Do we know, limiting the amount of administrators is still a question that we get, or I hear from a lot of, you know, banks that are that are reaching out pre and post audit. They’re saying we need to know who the administrators On our site, we have a pre approved, or we have a report that’s all generated for that. So you can just kick out that report. But when you’re preparing for an audit, you should know who has administrative access to your Facebook page to your Twitter profile to your LinkedIn content, Instagram, who has that access? And at what level? Do they have that access. So Facebook in particular does have different roles and responsibilities. But you do want to know, who has primarily the ability to post content, if they don’t have the ability to post content that’s not quite as relevant. But keep in mind if that’s an advertiser on your platform, and we’re going to talk about advertising heavily. That person does have the ability to create an ad and publish it without your approval. So that’s something clearly to think about. Now, your analytics ones if someone’s ready requested analytics access to your Facebook page and you’re granting that all they really have the ability to do is generate reports and, and see the results of content. So not as big of a concern, because they’re clearly not going to be able to post that to that content. But a report for that is clearly something that’s important. Now, again, when we think of land warfare, everything revolves around taking the high ground. So we talked a little bit about, hey, it’s about understanding what we can see. So can we see all of our incoming and outgoing content? You know, do we know when something was posted with our approval or when something was posted without our approval? That visibility is something that I think is really critical for us to think about how we’re, how we’re approaching a strategy to reduce some risk there. Again, these tactics are are defensive in nature. That’s that’s sort of the the nature of our compliance role here is to figure out what our demands strategies when we talk about marketing, that’s an offensive strategy. These are all defensive strategies to figure out. Do we know when things are are happening? Do we know what sort of KPIs have been met? And whether or not we’re, we’re reaching those? So some of those KPIs might even be how long does it take us to review content. That might be a KPI that you have in place, and we’ve done some reporting for for different financial institutions that want to know that type of information. So a few a few pro tips to again help with that. One is, you know, write pre approved responses. If you’re looking at how things happen after the fact. You know, your speed to respond, even if you don’t use that pre approved response verbatim. Having it created before you have an issue will help you create a faster response.

Alexander Lahargoue 17:53
We got a great question actually along that line with preferred responses from Rhonda and she wants to know about how are some Have the banks that we work with handling social media complaints, specifically, from a response time perspective, confirming to the complaint isn’t an actual customer. And what do you consider to be a true complaint? Yeah,

Ben Pankonin 18:10
yeah. I thought we might talk about complaints today. Yeah, I’m glad. I’m glad we are. So when we talk about complaints, a couple key things that came through in that question one is, you know, how do we know if they are a customer or a customer? You know, one of the things I always talk about that I love about working in this industry, is that we usually know who our customers are, right? Now, as a marketer in a marketing role. You might not know you might not know that, you know, Sally is actually a customer when Sally posts to us, but very rarely do we see a complaint to a financial institution that isn’t from a customer or former customer wishing with one exception Sometimes it’s disgruntled employees, oh, yeah, we’ve seen those as well. But But usually they’re a customer, former customer. So when we see those that are a customer, former customer, you know, the first step is to figure out what actually happened. So I get a lot of those calls escalated to me. And you know, sometimes I catch alerts, I had one the night before last that was, you know, 1145 at night, we had a weird bizarre complaint that came in, in their case, they curse too much, and it got caught by our, our filter. So they they didn’t it didn’t get posted. But you know, it’s still something in that case that we still want to probably reach out to that customer and say, we noticed that you tried to post something, you know, on our Facebook page, and, you know, even though it didn’t get published publicly on their Facebook page, it still may be an opportunity to reach out to that, in their case, very disgruntled employee and ask them some questions. Hey, you know, I’m sorry that you feel that way? Is there something we can do to help? So I would say, when we start to look at the metrics of that, you do want to look at your time to respond. I think that’s one key metric. Facebook uses that heavily to understand is this page responding quickly. So I think that’s one thing you want to do. Now, your time to respond doesn’t mean the time to resolve. I think that’s a really key distinction, because your time to respond is letting them know that they’ve been heard, and that you’re seeking to solve their problem. Right. Right. And it may be as simple enough as saying, thanks for reaching out. I’m looking into the issue, right, that yeah, that

Alexander Lahargoue 20:46
could be it. How fast that response time come in, do you think

Ben Pankonin 20:48
Yep. And I would love to see that be an hour or less. Gotcha. Um, you know, I know some of you are hitting, you know, much smaller windows than that. I see it on your pages that you’re Hitting, you know, under 15 minutes on a lot of those, that’s phenomenal. But I would love to see that really hitting under an hour. Now, I realized that sometimes that comes in like that one the other night, it was 1145 at night, I happen to be up working anyway and caught it. But you know, you might not be able to respond all the time at midnight. But, you know, responding to those the next business day, if you’re thinking about your eight to five time period and saying, realistically, I should probably be able to get somebody to respond in about an hour. I think that’s, that should be a good average time for you to, to at least acknowledge the issue. And then you’re sending it to someone and having them do some research. If you’re not the person, have someone else do the research. Let me know what the story is. Did this where they charge some overdraft fees. You know, were they were they overdrawn or were they you know, typically there is a story there and to be It’s it’s not that long to find the story, usually it’s pretty quick. But you just have to have that person in place that can do research for you really quickly with a frontline person, whoever that might be. getting them engaged, really helps speed up that process.

Alexander Lahargoue 22:16
Right. I like the point you brought up earlier about there’s a difference between responding to the complaint and then resolving the complaint. That’s really interesting to think about.

Ben Pankonin 22:23
That’s right. And I think, you know, then you come back and, and make sure we are resolving it. Right. Right. That’s, that’s your customer service. You know, that’s really what we want to do. And ultimately, anyway, so we talked about land, those are the things that we know what’s going on. We can if we take the high ground and we have the right tools in place, we can see what’s going on we can see you know our defenses we can build up, you know, good walls to help ourselves, be defended in a good way. Now, when we think about air, this is this is a different tactical together, because air is a whole lot more about targeting, right? Right, we get to now understand what’s happening where. So one of the things that we want to understand is that in the air, a lot of times, we’re guiding people and directing them to different places. People need to know that what we’re doing, and we need to make sure that it’s very specific. So one click rules are something that we really want to have in place. So if you’re pushing any content out that is product related on social media, we need to make sure that any necessary disclosures are within a one click from that. So that could be that you posted out that Facebook post and you you’re putting a link in it, and that link goes back to your site. It could be that you’re posting had an image and then you’ve got a link, because maybe you’re doing a contest. So if you’re doing that contest, you’re pushing out a an image Like engage that sort of thing. And you want to have rules in terms of guidelines for how that actually works, it’s great to put a link in there doesn’t even have to be clickable from that image, it could be just a clickable link at the bottom of that description. So that is actually present there. So there’s a lot of ways to do that. But making sure that those one click rules are applying there. Now, the big thing we want to talk about in the air strategy is that it’s about advertising. So when we think about advertising, one of the things you have to think of is every time I create an ad on social media, I am making a determination on who gets to see this post. And ultimately, then I’m making a determination on who doesn’t get to see this post. Now, what that means is, you know, for those of us who have been involved with maybe print campaigns, or you’re still doing some direct mail, that direct mail campaign, when you’re sending that out You’re making that same sort of distinction. But we’ve sort of pre baked in what our audience has been historically. So we’ve said, if they’re within x miles of the branch, or they’re within this geography, that’s who we’re going to advertise to, what we often forget about when we do social media advertising, or any sort of digital advertising is we’re creating a specific audience. And yes, that audience may be discriminatory in nature, but by nature, it is discriminating against who sees it and who doesn’t see it. And so we have a number of laws and regulations that come into effect. And so we’re going to try to touch on as many of those as we can in the short amount of time. But this is really where things get dicey. And this is really where we want to figure out, Hey, how are we targeting those? So we’ve got a little, you know, option over here on the right where we’re targeting a group in Omaha, right? We’re saying hey, geographically This is so much distance from a location. And we can make that type of thing on Facebook, Twitter, wherever we’re making that, even Snapchat. But, you know, we’re also able to target with certain demographics. So we could

take certain demographics, that could be based on interests that could be based on behaviors. There are a whole level of segments that we can figure out how those are done. Now, for some of you, you’re just doing geography. And that’s really the easiest. If you’re publishing out and saying, hey, I want to target people within 20 miles of a branch location. That’s really simple. But a lot of times we go to a conference, and we have somebody, especially if they’re outside of banking, coming in and saying, Hey, there are so many different ways that you can target. Yes, there are, but some of those are completely not applicable. If especially if you’re Marketing alone based product. And so we’ll talk about some of those. So we talked a little bit about disclosures, a little bit about clarity. So we’ve got some Truth in Lending, we’re going to talk about over some of these ads. But that also applies to Facebook as well. So Facebook, Twitter all have their regulations. This is actually part of the statement out of Facebook’s comments on what ads are permitted and what ads are not. And so, you know, they mentioned things like Bitcoin, and things like that if you read further, but really what it’s saying is, it can’t be misleading or deceptive. I have watched some products get flagged, some of you have probably experienced that where you’ve had some ads that you got that you created, were flagged, a lot of times that’s because they’re not quite

Alexander Lahargoue 27:50
clear enough.

Going back to what you’re talking about earlier with building audiences for our targeted advertising campaigns. We’ve got a great question from Lauren who asked whether We can target demographic based on age if the product itself is also age specific, for example, a senior checking or a student checking account.

Ben Pankonin 28:08
Oh, that’s great comment. Yeah, the short answer is yes, you should be able to, if you’ve if you’ve made that determination. Now, what I’m also hearing you say is those are depository products. So we have a bit more flexibility in our depository products. Because we don’t have Truth in Lending types of opportunities in there. We don’t have the same community responsibilities that are either, so your depository products, I get a little bit more freedom to do some of those things, especially if I’ve determined that up front. What I’ve also seen some financial institutions do is just segment them and say, Hey, we’re going to create an ad that is student paced, has images in it, that are student focused, we’re going to advertise that to the student group, then anyone who’s older than that, you know, we’re going to have Have a more generic ad that might, might appeal to that. And then, you know, if we’ve got the 65 and up and we’ve got a different product there, we’re going to target that. And we’re going to run a campaign set. Those are different ads, fundamentally. But we’re going to cover the full age range.

Alexander Lahargoue 29:17
Gotcha. So depending on the type of product that we’re trying to market, we have more flexibility, given the regulate, regulate ratio regulation around it.

Ben Pankonin 29:25
Yeah, more, more or less flexibility. Hey, yeah, it just depends. Obviously, you know, respa, and Tila, restrict us a bit of what we can do on those. We also have different responsibilities when we’re looking at contests, giveaways, sweepstakes. So most of you are doing some sort of contest giveaways, sweepstakes on your social media profiles. A few things we want to talk about. One, and we’ve gone over this before, but there’s a fundamental difference between a contest and a giveaway or sweepstakes. The easiest way to think about those would be that a, a contest has some level of skill applied. So there’s an effort skill, some sort of merit that is required. So we have different terms when we’re creating a contest than when we’re creating a giveaway. So a contest, obviously, we want to be very clear about what is the skill that we’re looking for. If we’re having people upload a photo, and then vote on that photo, that would enter us into that contest area. Now giveaway or sweepstakes, a lot of times we’ll just have people like a photo right says like a photo. That’s kind of the most common one. But it might be, hey, we want a little bit of your information to register. There’s a few other things that are coming in that area that’s that get to be really interesting as well. If you’re having people enter the contest, and you’re having them enter with their email address name. You want to think about where you’re putting that email address as well. So are you asking them to opt in to further emails from you? That would be one of the questions that you want to ask and think about. Also, depending on where you are, California is starting to pass some legislations that are bordering on similar to what we experienced a year ago from GDPR. So the European laws that are restricting how we gather information from Europeans, that is something that you might want to be thinking about and at least putting on your radar because it’s coming. We’re going to have some regulations, probably in 2020 that come down about how we collect email addresses and contact information from people on the internet. We don’t fully have that now. But that’s definitely something that you want to think about. Where are you storing that information? How are you gathering at that? Have you have those people granted you exclusive have permission to send you follow up emails. So those, those are important things to consider. Those aren’t all inactive now. But I think that’s something that you definitely want to be thinking about as you’re looking at your digital strategies. So we talked about contest giveaways. And then there’s the The third type, which is lottery. I actually just had one that I reviewed for a bank, probably about two months ago, that it by definition was a lottery that they were running. So the difference between a lottery and if we look back at these contest or giveaway, so a contest would be, again, something that requires effort or skill. A giveaway is something that is random chance. Now, a lottery is something that requires investment. So if I’m asking someone to make an investment, and now making an investment might mean opening And then count, which was the case of the one that I reviewed. If you’re asking someone to open account, take responsibility like that, and then they would have a chance to win. Now you enter into the lottery territory. So that’s definitely something that you want to review very carefully. Because not only would a regulator that would normally audit you be frustrated, but with that, but you might have the lottery commissioners or some other organization that might review that, as well as Facebook. Right would not look favorably about that either.

Alexander Lahargoue 33:34
We got a question from Alyssa about trends that you’re starting to see on social media. Are you seeing more financial brands turn towards giveaways and contests to increase their following on social media?

Ben Pankonin 33:44
Yeah, you know, we are, I don’t know if it’s more. We had a wave of like iPad giveaways A few years ago, or some of those things that were that were really common. I think we’re starting to see them be more common. And more related to the brand of the bank. And I think that’s something that is actually really encouraging to me because it’s not just about giving something away. It’s also about tying it into your financial institutions brand, so that you’re seeing results that go beyond just someone wanting to win something, but somebody who’s buying into your brand in that type of contest or sweepstakes, so that’s what I’m seeing. And I’m really encouraged by that part of it, because I think it’s, it’s not just about giving someone an iPad or having people, you know, try to enter to get that. I think it’s, it’s much deeper than that. And so when we see that, I think that’s getting exciting. We’ve done some really cool ones where, you know, we’re talking about stories of nonprofits or, you know, here’s leaders in your community who have given things away or, or have given a whole lot of their time we want to enter in those stories and select, you know, select someone out of that. You know, we’ve seen you know, some really cool giveaways that really just kind of tie into that banks brand. And I think that’s a growing trend. And we’re still seeing a lot of the the smaller gifts and giveaways things like coolers things like, you know, a night away for the family, movie tickets, you know, all of those sorts of things. And I think those are working pretty well as well. So few other campaigns, you do need to clarify that your campaign is independent of Facebook, Twitter, LinkedIn, whatever the platform is, that’s important to have in there. Actually, Facebook does require that you’re doing that and then make sure all of those rules for a campaign or contest are clear. Obviously, the no purchase necessary is that first part that’s making that clear distinction for us that it is not a lottery. And then when we make we actually have to make sure that our contest doesn’t require a purchase or investment.

Alexander Lahargoue 35:54
And along those lines, we’ve got a great question from Laura. Lauren just now who asked Facebook doesn’t allow you to always So we’re in a post that requires a like, or a share in order to win the contest, correct? Very true. So yeah, several

Ben Pankonin 36:07
years ago, Facebook pulled away some of our functionality in that regard. Originally, we were able to if some of you remember back in the day, we were able to actually like gay campaigns. So I was actually able to make apps where I could say, this portion of the contest was not visible yet until you liked the page. It was actually great functionality, because we could basically inspire people to like the page so they could see the rest of the content, right, all the details. So that was great. We picked up a lot of likes in that way. Then that migrated back to Facebook saying Nope, can’t like gate anymore. And then Facebook said, If you promote a post that requires liking as a as a portion of it, you have to pull that away. Now you can still say hey, go go like a photo in order to participate in the contest, but you can’t Say like this page in order to be a part of the contest that’s actually not in Facebook’s regulation, encourage them not

Alexander Lahargoue 37:06
require them to like your page,

Ben Pankonin 37:07
right? You can still ask for people to like your page. You can. Yeah, there’s a lot of ways to subtly do that. And you’ll see some of the copy that we do to help inspire people to do that. But they don’t actually have to

Alexander Lahargoue 37:20
go. We have another great question from Samantha, who asked if the contest giveaways and sweepstakes that we plan to have on social media need to also be available in the physical branches. So that way, it’s open to all customers online and offline.

Ben Pankonin 37:34
Yeah, so um, so there’s a number of ways to do that. There actually have been some good responses that have said, Hey, you can make that a public link and you’re okay. There’s, there’s several ways to kind of handle that one. One of the ways is to handle it by by requiring them to mail. So you’ll see those at the back of your cereal box or stuff like that where it says, Hey, you can mail this in In this coupon, whatever it is, you can mail it into this address. And I don’t think General Mills gets very much mail from that. Like, there’s just not very many people that are doing that. And so we’ll often do that put those in the terms that you can mail in an entry if you wanted to mail in an entry. Of course, nobody ever mails in an entry. People don’t know how to use mail anymore. So yeah, it’s it’s kind of a funny process, but that’s one of the ways we’ve seen it done. Okay.

Alexander Lahargoue 38:32
And then another question from Savannah, who asks, Is it allowed to ask people to review your bank and then return it? have them be entered to win a swag bag?

Ben Pankonin 38:41
Ooh, interesting. That technically depends on the platform. Okay. Um,

you know, in general, asking for reviews in order to get to get something is typically frowned upon. Okay. I’ll say that That’s typically frowned upon. However, I very much would encourage you to ask for reviews. So oftentimes you’re doing that, specifically, when you’ve had a positive experience, training frontline staff to say, Hey, would you mind reviewing us? Now, there’s a ton of review sites. So we just went on a trip. And you know, TripAdvisor is the is the place you often are looking at, right? When I look at restaurants, I’m often looking at Yelp. Shit, don’t look at Yelp very much anymore. I mostly use Google. Because I know that behind the scenes, people are paying Yelp for better reviews. But oftentimes, what you can do is say, hey, you just had a great experience. Would you review us on Google? Or would you review us on Facebook? And then if you were to give them something as a thanks, I think that’s the often the better way to do that. Of course, you’re just piping piping an already positive customer, but I think, in general that provides a lot of goodwill as well. So, yeah, those are good questions. So, you know, another one to think about is, you know, when you are partnering with with someone, you have to understand that they need to understand bank regulations. They also need to understand things like copyright infringement. So some of you may have noticed this this week that, you know, I was both Iowa Hawkeyes and Iowa State’s both have suspended Twitter accounts right now currently, I actually checked it again this morning. Their accounts are still hidden as well as I believe is Rutgers. And was there another one I was missing Alexander

Alexander Lahargoue 40:47
the Houston Rockets. Oh, the Houston Rockets,

Ben Pankonin 40:48
right. Yeah. We’re all suspended by Twitter this weekend are still suspended for using copyrighted material in their tweets. So believe it Was copyrighted music in some of their videos. But when you’re thinking about hiring outside people to help you with social media content, whether that’s an agency, whether that’s, you know, an intern who comes in whatever that is, you’ve got to start thinking about these things because this the threats are legitimate. That, you know, in their cases, I believe those were suspended on Saturday, and here we are a Wednesday, they still have no access to their Twitter accounts offline. These aren’t Twitter accounts with 1000 followers. We’re talking to a quarter million or more followers in all of these Twitter accounts, right. So these are large, high profile Twitter accounts that are suspended, you know, going on five days now at this point, so be very careful about those. Also, we’ve seen a trend of inviting someone else because advertising is such a difficult process and staying on top of advertising and getting that to work. If you’re looking for somebody outside the industry to do your advertising, they need to understand respa Tila, they need to understand what sort of products, you’re marketing as a financial institution and the implications of that. Because you’re ultimately liable for that if you granted them access to create ads on your behalf. So at a minimum, be able to review those ads before they go out. But if you are reviewing any of those ads, that’s also a huge concern. So this is, this is one of those areas where, you know, if you’re not managing it, but make sure if you are managing it, make sure nothing’s copyrighted, make sure you’re understanding what those advertising implications might have.

Alexander Lahargoue 42:45
That’s a great point. And we got a question from Megan who asked if there is any specific language that might appear in an ad that will cause it to be disapproved by Facebook.

Ben Pankonin 42:58
Yeah, so the Short answer is obviously ad hate speech, things like that. I think in our space, I’m not seeing very many financial institutions that are using hate language. Right. What I have seen, as far as disapproved content, obviously, you have restrictions on images, those are probably the most disapproved content is that they use too much text in an image. And Facebook will say, Ah, you know, we’ll still place this ad, but it’s not going to have much reach, or we’re not going to place this ad altogether. The third category of disapproved ads would be that they’re too vague. So if you’re putting something out there that says, we have the lowest interest rates in our county, like, I don’t know what that means, like, yeah, you know, I don’t know what the interest rates on I don’t know what the product is. I don’t know how that works. And Facebook actually clicks through the link. So if you’re setting up a landing page after that, and you don’t have clear disclosures that are present that say this Is the product, this is what we’re offering, this is what the deal entails, then they’ll disallow that. So you know, can’t be just, hey, here’s a generic web form, give us your name and phone number. In order to qualify for this loan, you’re gonna have to be more clear and explicit than that. That’s the kind of thing that we’re seeing. Probably most common is that there’s just too much vagueness in the ad. And I get that it’s hard. There’s not a whole lot of real estate to make that in the ad, which is why a lot of that does have to be on that one click page. So a lot to cover at the end of that one. And I think, you know, clearly, that’s the area where if you’re looking for where we might not be compliant, those are the areas where, where you should probably have the most concern in your advertising, if using any third parties to manage any of that for you. You know, how you’re making your images and materials, making sure that those are

unrestricted. Copyright access. So, right,

clear. Now, when we talk about battling at sea, we talked about the defenses we have there. This is what’s changing. This is where we don’t know what’s next. But we did have some questions early on that I thought were worth talking about a little bit in what’s changing what’s happening, what’s happening. Now Facebook has been making a lot of changes to their advertising. Some of this has beneficial to you because they’re actually taking out some of the, the demographic targeting that they had before. So no longer can i target on Facebook based on things like race. I was able to do that up until very recently. You could target on some topics like that clearly. Those are some some things that Facebook’s kind of reevaluating and saying, hey, let’s not let’s not do that. There’s just too many problems. So you’re seeing some of the things that Facebook is pulling out of there. So they’re changing things like ethnicity, color, national origin, religion, things like that they’re pulling those out of Facebook’s targeting algorithms. So that should help protect you to some degree. So targeting restrictions, you know, help minimize that risk. So I think that’s helpful for a lot of us. Now, you know, we also kind of want to target people in a specific area, but not too tight of an area. So I think that’s one of the things that we we still want to be very careful of with pixel or with our Facebook tracking. I also think that a lot of times, I’m seeing one of the most undervalued ways that we’re doing targeting is still retargeting people who have visited your website. At some point, if you’re not targeting people who have visited your website, you’re missing out on some huge opportunities, because it’s one of the cheapest ways To market as far as digital marketing, because those people have already expressed interest by showing up on your site. So when I’m listing how I’m targeting, and again, if when you’re creating those ads, you should be listing here’s where, here’s who I’m targeting. Here’s what my audiences. So when you’re putting that into your marketing binder, or your, you know, in our case, printing out the marketing binder or giving access to that marketing binder, at the end of the year, when you get when you have an audit, they should be able to see who you’re targeting in that landscape. So when you can say, I’m targeting people who have visited our website, or this portion of our website, that’s a really easy one. Because it’s a great way, they’re basically self selecting that they might be interested in that product rather than us. You know, pushing that out to them. So again, the other thing that we’re seeing a dramatic change in is platforms like Instagram and Snapchat are they’re trying to get more business friendly. So I think that’s going to be a positive. I think it’s going to be Easier to market and advertise on Instagram over the next couple years, that’s also going to probably drive up the cost of advertising on Instagram over time. Right? As things get easier to advertise on, typically your price starts to get higher. And it gets, it gets a little bit more expensive per person you’re reaching.

Alexander Lahargoue 48:18
And we had a great question from Kerry about this on that. These are new social media channels that banks are moving on to is the compliance process for these new platforms the same as it would be for Facebook?

Ben Pankonin 48:29
Yep. Good question. In general, I would say the compliance process is the same. You know, your policies should be the same. You know, if you look at the FF IC guidance, they did a really careful and kind of funny job at trying to be inclusive of a lot of different social channels. They’re probably the funniest one that they mentioned in there was a was a platform called Second Life, which was, if you’re an office fan and believe is one of the first seasons of the office. They make Fake Jim, he’s actually making that on Second Life, where you sort of go out, it’s kind of like SimCity. But you make your person has kind of a second life in an online world and they go around and interact with the world was actually mentioned in the fmic Guide. So there’s a little trivia for you. If you’ve never read the FDIC guidance on social media, funny little nugget there. But what they’re trying to do is say, hey, as these platforms change, the rules around those platforms should still conform to the same type of guidance. And that is that we do want to archive all of that content, which presents some significant challenges still, for platforms like Snapchat, because we can’t archive that effectively, you know, Instagram, we can, but Snapchat, you know, has some has some real difficulty, you know, maintaining that presence in the business world. with some exceptions. Some of you are doing things like Snapchat filters. Those are actually pretty easy. You know, we can go out and buy a filter. For a specific area, I think that’s a really easy way to just at least get your brand message in front of people, especially if you’re doing major events. So if you’ve got an event in your location, pushing out a Snapchat filters a pretty good way to do that. Another thing that’s, that’s always changing his hand, we mentioned a little bit about his places for reviews. You know, we have so many different platforms and places to look at reviews, that that gets to be a real challenge for a lot of people. So when I when I’m doing reviews, obviously, I’m doing that on a per location basis. So I’m going to this branch location is the branch that I’m reviewing. I’m not necessarily reviewing the bank as a whole, which presents some other challenges. You know, I have seen some questions come up in FDIC audits, about reviews and locations. So I think that is something that definitely you want to be considering how you’re reviewing Those. So we have a couple tools for that. One is our general search terms where you can just put in search terms and that’ll catch catch a lot of it. But then, you know, platforms like Yelp, you know, the only way to get review data back from them, is to pay them for a premium listing. Do I like it? No. Do we help financial institutions to do that? Yes, we do. You know, I believe we have 70 some different review sites that we we can push reviews and updates to. But I think that’s definitely something to take a look at. If you’re not doing that already.

Alexander Lahargoue 51:35
You know, and on the topic of reviews, we got a question from Shannon about how can financial brands gauge their own and review their own performance when it comes to either their presence on social media or even their own marketing compliance efforts?

Ben Pankonin 51:47
Oh, interesting. So she kind of wants a scoring. Exactly. Yeah. Well, I typically don’t score. But But I like the concept and I think it’s something that what I would consider Looking at is setting up some of those key those KPIs, then for like your compliance, so maybe that is you’re looking at what’s our time to respond, hey, let’s put a number out there. Here’s what our, you know, we’re, if we’re aiming for an hour to make sure we at least acknowledge everything eight to five. And then you know, that gives us a score, right? We can go, we can go track against that. I would look at, you know, how long is it taking us to review content? How many negative reviews are we having? I think is a good one. And then I think, you know, we want to think about, Hey, you know, do we feel like we have a handle on where content could come in locations. That’s one of those spots. That gets a little tricky. For those of us use our platform. We did just release a feature to manage Facebook reviews. So if you haven’t checked that out in the social tab, that’s pretty cool. It just showed up so it works. If the nothing you have to do, but you can go in and look at your reviewed locations over in that spot. If you’re looking at, you know, maybe, Hey, how are we handling advertising? Do we feel like we know for every ad we created, what the target audiences and how we archive that? I think that’s a great question to have answered. So if I was trying to put together kind of a review system, I would look at first, do we have visibility to all of these areas? And I think that’s where I would start scoring. That’s a great point. I think for most FiOS, figuring out whether or not they actually can find all of that data is probably the first step.

Alexander Lahargoue 53:37
To Great point. Yeah,

Ben Pankonin 53:38
yeah. So good questions. So you know, managing online reputation, whether that’s, you know, review sites, or, or those social media challenges. I think all of those are particularly relevant. And then you know, one of the things that we talked just briefly towards the beginning when we were talking about just decided You’re decision fatigue, how do we help remove that one of the ways is to, is to create pre approved responses. So creating pre approved responses, you know, for a variety of areas will help you respond quicker. It will also help you think about potential emergencies before they become an emergency. So I think that’s a valuable exercise for you in just thinking through, what would we do in these types of scenarios? So it’ll give you a at least a list to start from. Mike, you know, we usually share out some suggested pre approved responses, but I think it’s good to say, hey, some of these might be blanketed. Some of these might be Hey, we would like to take this offline. Some of these might be hey, here’s a direct message. Here’s how we would respond quickly. And you know, we didn’t talk much about CRA but I think it really is something that we should be hitting every time we’re talking about this compliance space and how that applies. And there’s certainly some C’s of change around CRA that I think are are relevant to talk about. But, you know, we do have to think about census tracts. So when we’re talking about community opportunities, and are we allowing low to moderate income people to be to be targeted within our ad sets, that’s definitely something that’s CRA applicable. So when you’re creating that audience, that’s a very important piece. You also are needing to do complaint reporting for CRA, so if people are complaining about not having access to certain loans or certain opportunities, that’s definitely something you should be tracking. So that would also include online so if people are talking about being rejected, for loans, things like that, that could fall into your CRA audit. And then there’s obviously you know, lending opportunities and so sharing what lending opportunities are available with CRA and even promoting and pushing some of the options pertaining to low, low to moderate income individuals could help stimulate a CRA strategy. Yeah, that’s a great point. So, you know, we did have I think you said we had some questions come in for, for a DA compliance as turned on, I’m not going to hit this at a high level, but a few things that that you may consider the platform’s themselves. Obviously, we don’t get to change Twitter or Facebook, and those platforms. There are people with disabilities who do use those platforms, and Facebook, Twitter, LinkedIn, they all have requirements to be ADA compliant as a website themselves. So that’s definitely something that you don’t have to necessarily worry about by using those. But when you are pushing content there, that is something to a I think, just think about considering but be there’s there’s a little bit of debate as to what you need to do, specifically around things like videos. So if we did a video in interview, does it need to have closed captioning or subtitles on it? I would actually say most of the time, I would err on having those, in part because it actually helps your video a lot of times because a lot of people will have their sound turned off. And you might be able to have a sound bite if you’re doing an interview at the very beginning, when you’re describing the text of what’s being said, that actually could be really valuable to capture people’s attention. But you know, whether or not you have to have it, there is still a little bit up to debate. So, so just a few things to touch on on a DEA compliance. Obviously, the big concern for ADA compliance is your website. We don’t do websites, but I definitely have had a lot of conversations with people who are revamping their websites. And there’s a there’s a whole strategy around that that’s, that’s really important.

Alexander Lahargoue 57:52
But banks shouldn’t shy away from using video and their social media for

Ben Pankonin 57:55
No, absolutely. I think I think video is very critical to be thinking of those. Now. I know We We’ve had a few people that are probably a little bit more versed in military strategy than we were in kind of our loose interpretation about land, air and sea. And and there’s two other areas that actually fall into the military domains back in the 90s. Just kind of interesting to note, one of those is space. And one of those is information. And, you know, everything that we’re doing, I think Does, does have to fall into that. And so when we, when we extrapolate out that example, I think, when we think about space, keeping up on what’s changing in the next frontier, I think, is really critical. So following along, for many of you, it’s it’s checking in our webinars like this, some of you are inviting young people within your staff to to be a part of conversations to say, Hey, what’s coming What’s happening? You know, I get a lot of feedback from young people as well. How are you using Snapchat? Why are you using it? Why are you getting your news from Snapchat? Those are some of the questions that I’m interrogating young people at our office about, but I think those are really in Important, you know, to continue doing in our own learning, and then information. Obviously, we are in the information business. And I think it’s critical for us to be thinking about all of the information that surrounds social media, our products, and how we’re getting good feedback. So when we are getting a number of complaints that say, hey, there’s some challenges with the mobile app, maybe that’s some stuff we need to we need to take an internalize and figure out how to figure out so you know, getting some reports in and seeing all of your posts in and figuring out where your negative posts are coming from and what they’re pertaining, I think is really a great place to start as well. It’s a great point. Yeah. So we had a lot of good questions. You know, obviously, we’ve got some continuing education opportunities by staying, staying in tune with our webinars and some future webinars. We’ve got some upcoming webinars. I know we’re going to be featuring some things with images coming up in one of our next webinars will kick you a reminder will also send throughout a recording of this webinar, so if there’s other people in compliance or around your staff that you’d like to make sure educated, you know, feel free to pass that along. And thanks for joining with us today. It’s been a great and quick review.

Alexander Lahargoue 1:00:14
Yeah, it was a great webinar I thought