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When things are done right you have to communicate it to others.  I was given permission to share with you, what I think serves as a great model for others who are struggling with marketing compliance.  A year ago it was not uncommon for loan originators to have their own web pages, under their own “team” or “group” name.  Nor was it uncommon for Facebook pages, Tweets and emails to be sent that were not reviewed for compliance.  In fact, for many companies this is still the case. In today’s world, none of these loose practices will fly with the CFPB.

Step One:  Herd the Websites

Each originator can still have their own identity, but they can no longer be a rogue agent.  This can be a tough thing to do since many top originators have created their own identity over the years.  So the first thing they did was a complete overhaul of their web presence while at the same time providing individual pages for their originators.  Compliance and Marketing worked together to make sure that the look, feel and set-up met with the compliance standards of today and marketing made sure it was relevant to get business in the door.  They then created policy regarding the use of your own sites.  Additionally, they mapped all leads to go directly to the individual loan originator so that business would not be missed and management could monitor the outcomes.  Each loan originator has their own web address to advertise on their collateral material.

Step Two:  Corral Social Media

This means consistent googling, policy and procedure around what your employees post.  Tracking and archiving posts need to be set up as well.  This means approving some messages, creating some example messages and archiving all messages.  When compliance approves messaging, it gets archived.  If anyone deviates from this policy, management can be informed because of the monitoring in place.  It is important to communicate the difference between personal messages which are an employee’s private business, versus use of the company name or services provided which is not private business.

Step Three:  Rein in the Marketing Materials

The next step was to take the marketing materials in existence, make them compliant and expand the availability of more and consistent materials.  This involved compliance and marketing working together again to ensure that the information being communicated such as the contact information and disclaimers were in place.  It also required marketing to create the same look and feel, while still maintaining individuality for the originator.  Additionally, policy and procedure were locked down to ensure that formats could not be changed and other areas could be changed, to accommodate individuality.

Step Four: Ride the Technology Wave

How do you make sure that 300+ originators market the same way and in a compliant manner?  Take it out of the originators hands while ensuring that they are happy with the results.  This means defining a campaign that occurs automatically and uses technology, during the processing of the loan and continues as a campaign after the loan closes.  To do this, you need to tie your marketing to your pre-created milestones.  When a file reaches a milestone or date, a video message or email is sent out.  All of it is archived, time stamped and compliant.

 

Tammy Butler, Master CMB

Author Tammy Butler, Master CMB

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