Pub. 2 2014 Issue 1
winter 2014 11 The newsLINK Group, LLC is a marketing firm that specializes in communication strategies for nonprofits, trade associations and professional service firms. Mark Your Calendars and Plan to Join Us June 29 - July 2, 2014 in Sun Valley, Idaho Utah and Montana Bankers Association’s 2014 Convention the U.S., FINRA created a Social Networking Task Force to study how communication rules should be applied to social media sites. • The remainder of the document con- sists of questions and answers that have been grouped according to the general topic; for example, a section about types of interactive electronic forums contains the answers to two specific questions. FTC The FTC document has guidelines for using endorsements and testimonials in order to advertise a product. Each section consists of a general explanation followed by a series of helpful examples. The sec- tions are organized as follows: • Purpose and definitions: The FTC uses this document to tell readers how its administration interprets the laws that it enforces by explaining the general principles, defining the terms (endorsement and testimoni- als, endorsers, products, and ex- perts), and then lists examples eight examples of situations that are or are not categorized as endorsements. The last example deals specifically with a personal blogger. • General considerations: This section contains about the general rules for making an endorsement. For example, it is illegal to lie about your opinions when you make an endorsement. As with the previous section, there is one example dealing with a blogger. • Consumer endorsements: The idea is that if you endorse a product, you need to have enough knowl- edge about the product to make the endorsement, your own experience needs to support the claims you make, and if an ad claims that you are an actual customer, then that has to be true. If you are not an actual customer, then that information has to be made plain. • Expert endorsements: If someone gives an expert endorsement, then that person must have the necessary credentials to make the endorsement and the endorsement can’t be decep- tive in some way. • Endorsements by organizations: Organizations consist of people with many different opinions and, often, different levels of expertise. If an organization endorses something, therefore, the organization has to have some kind of process in place to ensure that the endorsement really does fairly reflect collective opinion about a product and also that the organization as a whole is qualified to make the endorsement. • Disclosure of material connections: If a business hides information that would reasonable affect the way someone evaluates a product, then that information has to be disclosed. Two of the examples deal with social media (the first involves a blogger, and the second involves an online message board). Summing Up Part of being a banker is being prudent, thorough, and methodical. Many people consider these to be old-fashioned virtues, but the truth is they continue to be useful because they help financial institutions stay out of all kinds of trouble, legal and otherwise. Social media may be new, but applying these virtues to your policies and procedures will go a long way toward keeping you, and your company, away from the court system and the kinds of headlines that no banker ever wants to see.
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