Social Media - One Click Away

I am in the process of doing an advertisement review on our social media accounts. As you know, social media posts are on the internet indefinitely. Our posts use the "one click away" method to disclose the information required in the post. However, I got to thinking about the links the disclose the information. Those links can stop working, disappear, etc.

So if the link is no longer working, what would we need to do to prove compliance with the one click away rule? Also, how long would we need to retain the "evidence" of compliance. Any help would be appreciated.

Careful, the only "one click away" allowances are within TILA and TISA that I'm aware of, I see this misunderstood pretty commonly by marketing teams.

Sorry, to your question, retention would depend on what is triggering the disclosures. What I've seen used in the past is a mock up screen saved with the rest of the advertising details, so even if the link isn't working by the time regulators ask for it, there is proof of the disclosures as they were at the time of the ad.

Thank you. It is a TISA post.

Monster....thank you for pointing out that "one click away" allowances are within TILA and TISA....I think you have confirmed for me what I told marketing about social media posts for investment products and FDIC information is correct.....marketing wanted the Not FDIC language to be "one click away"

I said that the Not FDIC insured information for investment products could NOT be "one click away" because this was not associated with a "trigger term" but was associated with the PRODUCT.....I did tell marketing that they could use the shortened version with the 3 mandatory disclosures----Not FDIC Insured; May Lose Value; No Bank Guarantee....

I did tell them correctly...didn't I??

I do my best to work with marketing and want to make sure that when I tell them they HAVE to do something that they do in fact HAVE to do it.....

Please help me make sure I am thinking correctly. The graphic in the social media post is considered the actual ad, and the one-click-away link should be embedded in the graphic, not just a "click here to learn more" link in the comment that accompanies the graphic. Is this correct?