Social media - what once was a strictly personal space for interactions with friends and family has inevitably evolved into a bustling advertising arena, where the lines between business and personal are blurred at best. Entrepreneurs, like mortgage loan officers, are using this free advertising medium for business partner networking and marketing to consumers alike. But the common question remains - should they use their personal profiles or create a business page?
Facebook created the Pages for Business feature back in 2007 in an effort to create a space for business owners to market their products or services and for consumer users to connect with those businesses. This Business Page model is commonly used by brick-and-mortar stores and restaurants where consumers might check-in, but many small businesses and lone wolves of the sales force, like mortgage loan officers, have also flocked to the Facebook for personal brand promotion. There have been many changes to both sides of the platform since then, here are some key distinctions:
Facebook personal profiles and Facebook business pages have different fields and character limitations associated. For example, Facebook personal profiles do not allow for license numbers to be added to the account name. All employer and licensing information can be added to the Work sections instead, but only Company & Position reflect in the profile Overview. To see full licensing information and disclosures, consumers would need to click through multiple fields. Also keep in mind these field must be set to "Public" to be seen in the first place.
The FTC has outlined in their .Com Disclosures Guidance that consumers should not have to click more than once to see all necessary disclosures and licensing information. This means, in order to be in compliance, all advertising posts shared on a personal profile would need to include: a full licensing disclosure, equal housing information, state by state disclosures, company specific information, and any relevant product advertising disclosures. The one-click rule is much more achievable with Business Pages where licensing information can be included in account names and additional disclosure information is readily present on the About page.
We've seen it time and time again, a news story about a company employee making poor or malicious decisions on social media that have a negative effect on the companies public relations for years to come. In one story outlined in our Corporate Social Media Horror Stories article describes how one employee for a financial institution used racial slurs on her social media profile. Other social media users were able to quickly identify where the employee worked, and contacted the company directly about the inappropriate language. Though the employee was terminated, various fair lending lawsuits were then brought against the company for years to come and negative consumer reviews began to soar.
Licensing and relevant disclosures are top of mind for regulators, but there are additional concerns with Facebook:
Social media use in the mortgage world feels a lot like the wild west. Compliance and marketing teams have so much on their docket that it can be difficult to devote time to discovering and remediating issues on their own. When possible, a best practice is to ensure employees are using professional pages when doing any product advertising or self promotion. Marketing departments can create business pages for individual loan officers, some electing to add themselves as administrators. Loan officers gain insightful metrics about consumer interactions with their online presence and compliance teams rest easy knowing that consumers and regulators alike see all the necessary licensing and disclosures.
Social media has been such a big part of our personal lives for the past 10 years. The number of...
Back in 2007, Facebook began the rollout of the now well-known Business Page model, allowing...