What is Considered ‘Advertising’?
Everything you do with the company’s logo and name on it is considered marketing. Even when it
is something small that you think doesn’t need to be approved, you are likely mistaken. When the logo is put on something it is then considered an advertisement, which requires us to document it as such. Please contact Marketing to help you out and to keep you and the company out of trouble. This may include but is not limited to the following items:
Event flyers. All events must be approved including the flyer or event used to market it.
Facebook posts (stay fun, vague, and as long as you’re following the guideline’s I have listed below in the social media section, you are okay to post without prior approval). Just remember that the guidelines only apply to prior approved art. However, once you put the company’s logo on something or mention the bank, it then must go through the formal approval process.
Co-branded flyers or co-branded ANYTHING. This includes sharing social media posts of industry partners. More information is provided in the social media section.
The list goes on! Reach out, we’re here to help!
This will always require contacting marketing before proceeding. Co-branding requires documenting the shared cost of the project, no matter what it is, to remain compliant. This means we must collect invoices/proof of payment and proof that the outlined portion allowed to contribute was followed.
You do not send these requests to risk management, they must be submitted to marketing (via the marketing submission found on wvbkthevault.com). Marketing will prep/send materials to risk management for you.
Co-branding is a feature in surefire that we hope to get approved in near future, however currently, it is not an option. We’ll announce when/if we’re able to get this program compliant. (Open House flyers are approved for use in surefire with Realtors information however since it falls under our Xtreme Open House Program).
Distribution of Co-marketing Materials
We are also required to document distribution and shared cost should the Realtor/Loan Officer be distributing the marketing material on their own or together. The best course of action is to always split these tasks to remain compliant. If the marketing material is being mailed, please inquire about additional fair lending rules we must adhere to.
How is comarketing different than cobranding? Cobranding is putting yours or someone else’s info on created marketing materials. Comarketing is where you share marketing efforts, meaning we are marketing on behalf of someone else and they are marketing for us. Please inquire with marketing@ wvbk.com for details to see if this process is currently approved or suspended.
The same way we don’t use an outside company to underwrite our loans, we don’t use outside companies to control our brand. For this reason, we ask every ad, flyer, etc representing WVBK and our employees, be created by the WVBK marketing department to ensure brand and compliance consistency. Go the marketing tab on wvbkthevault.com to find and submit a marketing request. All new design or marketing requests will come to us through this system and then we will begin your design based off the request. If our logo is on it, we design it.
It is a RESPA Sect 8 violation to give (or accept) anything of value in exchange for business to a Realtor or industry partner. This includes:
Gifts (hats, gear, promo items, anything.)
Social Media posts and shares can have RESPA risk. Employees should not share posts of industry partners. More information is provided in the social media section.
Companies are always looking for sponsors for their events, and it’s a good way to get out and support our industry partners, however, just keep in mind that we do have to document all of our sponsorships the same way we do other marketing that has our logo on it. Here is how to quickly get it approved:
Go to wvbkthevault.com and find your way to the sponsorship section of the marketing request page. This outlines the full process for getting events and/or sponsorships approved.
Prequalified vs Preapproved
The term ‘pre-approved’ has very specific compliance meaning and is not approved at WVBK. We have to ensure we are always saying ‘Pre-qualified’ instead.
Saying Things We Can’t Promise
We always need to ensure we are using terms such as ‘may’ instead of ‘can’ ex. “We may be able to save you money” never saying “we can save you money!”. We have to make sure we aren’t making promises as not everyone qualifies and not everyone can save money. This applies for many different types of posts, but is a good example to remember.
Giving something a time frame. ‘it only takes 2 minutes to see if you pre-qualify!’ Instead it is better to say simply “stop by to see if you pre-qualify”.
if you are stating a claim, it has to be true or we suggest finding alternate verbiage.
This includes but is not limited to, articles or websites that are featuring you or WVBK with your permission. These are subject to the same marketing approval process as all other forms of marketing. If you know you will be featured in something, please submit it to marketing the same way you would anything else. We are required to ensure the following is in place for all outside media: the article is approved, your nmls number is listed, our required compliance logos are used or spelled out (Equal Housing Lender. Member FDIC.)
Social Media Guidelines:
The following are requirements when posting on social media.
If you have a personal OR business page where you discuss any business related to WVBK, you must provide this information to marketing. You can do this by loggin into wvbkthevault.com, go to the marketing page, and choose the link ‘Submit social media links’.
Avoid the Use of Trigger Terms
A trigger term is using a word or phrase that ‘triggers’ compliance disclosures. These may include:
The word ‘free’ Acceptable alternatives would be ‘complimentary’, ‘no cost’, ‘no obligation’, but only if there really is no cost or obligation of any kind.
Descriptors such as easy, simple, etc. (WE can’t say this because from a risk perspective not everything is ‘easy’ or ‘simple’ to everyone so we are at risk of a fair lending violation if we say these terms)
Words such as expert, specialist, etc. unless you have some sort of actual certification. (Other alternatives that are okay though are experienced, knowledgeable, etc)
Mentions of rates or fees or points. If there is something you want to post, submit it as a marketing request if it mentions rates or fees or points in any way and we can work together to see if we can get it to something that would be approved.
Mentions of down payment percentages other than 0% or 100%. That is because any other value triggers us to list a loan scenario. If you do want to post something of this nature, submit it as a marketing request through the wvbkvault.com and we can work with you/risk to see what we can come up with to say.
Realtors and Social Media
We must follow the same RESPA Sect 8 guidelines on social media that we do for all other marketing. This means that our interactions with any industry partner can be seen as giving them something of value (verbal reference) in exchange for business.
We cannot share any industry partner social media post. You may like the post but sharing it could be seen as a RESPA violation.
Mentioning or tagging an industry partner in video/social media in any way.
We cannot mention an industry partner by name when marketing our open houses. This includes saying something like ‘hey I’m out here at 767 Ridgefield Road today with Julia Thompson from Keller Williams’. Can’t do that. We can mention we are there and the address, but no mention of the Realtor.
The ONLY WAY to mention an industry partner by name on social media is if it is done through an approved co-branding or co-marketing piece.
Do not describe the home. Ex. Beautiful 4bdrm, 3bath house with a huge backyard! (We had a loan officer get fined for doing this in the past as they are not licensed for this. Leave the home descriptions for the Realtors).
Giveaways are allowed but require prior approval. This is because we have fair lending guidelines we have to follow. When doing giveaways online, please do the following:
• Submit a marketing request through wvbkthevault.com and let us know the details of the giveaway. What you are giving away, quantity, how long the giveaway is open for, etc. We will submit that to the risk department for approval.
Do not use the word ‘free’ in your post.
No requirement of the giveaway can having anything related to a loan (ex. ‘Get prequalified and you’re entered to win’. It needs to be more along the lines of liking the post, sharing the post, commenting on the post, etc.
The giveaway has to be open to anyone who is on the social media platform and of any age.
Mention it is while supplies last. Make sure if you run out of the giveaway item that you make a follow up post or better, edit or comment on the post to say the giveaway is closed.
Posting Photos of Others
We are unable to post photos of anyone outside of WVBK without their written consent. This excludes sharing their posts or photo, that is okay to do. There is a ‘media release form’ on the vault under the marketing section you can download and have people sign.
BOOSTS or SOCIAL MEDIA ADS
Part of fair lending is ensuring we are not discriminating. Boosting social media posts may not be approved at this time. Please reach out to marketing for more information.