The use of online advertising is as hot as ever and the insurance industry wants its piece of the marketing pie. And who could argue with that? With practically everyone and their mom (Hi Mom!) having access today to the World Wide Web, the Internet can be an easy, accessible, worldwide “billboard.” However, whether you use a figurative billboard or a literal one, advertising regulations still apply. As the prevalence of online advertisements increases, so will the watchful eye of regulators, especially if complaints start to increase.
This is exactly what Stan Haithcock prescribes in his recent article “When an online annuity ad goes bad” (2013). Haithcock raises a number of interesting issues, such as the “one size fits all” problem of annuity advertising as well as the “need” for web promoters to mislead the public from the very beginning of the sales process. What stood out the most to me was his “call to arms” – not just to consumers or regulators – but also to other agents to begin “self-policing” the annuity industry. His suggestion? “Every time you see a bad pop-up ad or display ad, take a screen shot of it and send it to your state insurance department and the carriers whose product you think the “promoter” is pushing. Every time you see a video that is pushing the limits on facts, send a link to them as well. Demand that they clean it up. Demand that they do their job…” He doesn’t limit this to online ads – he goes on to say it’s time for ads, regardless of the medium, to be looked at under a “microscope.” That is a bold request and a risky one too.
Can you imagine what that could mean for individual producers, FMOs and carriers? Do you feel confident enough in your own advertising that if it gets sent to a regulator, you could defend what is being put out there? When it comes to sales, reputation is a big part of an agent’s livelihood. Imagine that your business was under the microscope of the state department of insurance. Even if no fine is given (and chances are, there will be a fine), that type of negative exposure can stick to a producer for a long time. We are often asked, “what’s the risk” of certain words and phrases that come up in ad review. This can be a difficult question to answer since regulations are broad and somewhat subjective. However, with others within the field looking for (and frustrated with) bad ads, there can be a much greater risk than what you might expect.
You have to remember, just like Facebook can be a treasure trove of embarrassing and damaging content for people going out and looking for a new job, the use of online advertising is easily accessible to anyone – consumers, regulators and your competitors. Before putting content out there, ask yourself if this passes the desk of your state regulator, are you prepared to defend it (and your business)?