Our advertising group wants us to do some Facebook Live streams to promote everything from an employee spotlight to a new CD special. The sessions could last anywhere from 15 seconds to 5 minutes depending on what is being discussed.
Obviously I am concerned about the advertising regulations. Since these will be live through Facebook, there is no way to do an overlay with the requirements. Is there any other way anyone can think of to get the information out there correctly? Poster board in the background? Compliance guy dressed in an a giant Equal Housing outfit reading disclosures?
Currently I have instructed them that we need to forgo anything that triggers the regulation and keep it more generally about employee spotlights.
Any help would be greatly appreciated.

Good question, Cracked. I'm curious to see your responses.

I wonder if you could follow radio media rules... Kind of a hybrid in that you don't have the ability to put any disclosures up on the screen. Interesting topic, indeed. Darn marketing people.

I agree. They sure help keep life interesting.
Well, this seems to have stumped a lot of people. I have posted here, another compliance forum and asked my external auditor. So far, no one knows.
I was hoping to find someone who had been through this, but maybe it's just too new of an advertising medium.

I suppose if it is going to be done, you really have to treat it as a hybrid of TV and radio. In a TV ad you would have the ability to put the proper disclosures up on the screen. In radio, you would follow those rules and announce the proper verbal disclosures.

If this were me, I'd approach it in a couple different ways. Put the visual disclosures up on the screen at the end of the stream, making sure it was both legible and on screen long enough to be read by a reasonable individual. The other option would be to treat this as a radio ad and read the disclosures aloud. In both events I would put a link on the stream that leads the consumer to the disclosures on your website.

Obviously I'm winging it here, no guidance for FB Live that I'm aware of.

Interesting indeed. Here is a comment from a consumer, not wearing my banker hat right now. As a consumer and FB user, nothing irritates me more than when someone or a page I follow goes live and that red button shows up notifying me of it and now I have to click on it to remove the red notification. So if my Bank had a page, and I followed it and it started "going live", I would never, ever watch it and I'd be annoyed. Just food for thought before you jump through hoops.

Word.

Same here! I avoid all the "live" feeds. If I want to see a news video, I'll watch the news. If I want to find out how to save money on my car insurance I will google it, NOT watch a video

Bringing this topic forward again to see if anyone has had any experience with this... or if Cracked found out more? My marketing department wants to begin live streaming on FB all of our seminars. I am concerned about the NCUA share insurance logo and EHL logo, where applicable. The first one up-to-bat is a home buying seminar. Would we also need to disclose the credit union NMLS#?

If this information was up on the projector screen in the room (legible on video, of course), would this be sufficient?

Thank you for any assistance!

I know that Cracked is at the RCC right now.

I agree with Norm's comment about the TV/Radio treatment of the ad.

However, since this is a relative new marketing avenue and the extreme potential for regulatory issues and penalties if not done properly why on earth is one not contacting their primary regulator for guidance.

I hope your marketing staff knows the negative potential for this plan from a consumer experience perspective., For example, see comments from P*Q and madukes above, which I agree with. Just because something CAN be done does not mean it SHOULD be done.

If a bank I followed started going live for seminars, I would unlike and unfollow their page, just sayin'.