Advertising on the Internet is just one means of promoting your business, but it has several elements to consider. While appearing at RESPRO’s regulatory seminar, Mark Meyer, founder and CEO of MLinc Solutions, and Charles Irsch, a partner at MLinc Solutions, spoke about how to develop an effective and compliant plan for advertising on the Internet.
Meyer first spoke about RESPA requirements and business strategies to consider.
“You should structure a web-advertising agreement that has the right wording and that has an acknowledgement that this is not an agreement or understanding regarding referrals,” Meyer said. “You’re paying for services, not an endorsement. Obviously you don’t want to have anything in the agreements that require exclusivity. That would be a bad RESPA fact.”
Also, avoid language such as “lender of choice,” “provider of choice” or “preferred,” and stay away from paying for direct sales pitches, such as paying brokers or agents to hand out brochures on your behalf. Some within the industry argue that this concept extends to emails going directly from an agent to end-consumers. Think about the cost of advertising with no direct relationship to what you get in return.
From a business perspective – to make sure your advertisements on the Internet and through social media, intranet and third-party web platforms are doing the most for you – Meyer recommends getting the advertising services independently valued by someone who doesn’t have any potential conflicts of interest, and, when you can, setting conservative flat fees to allow for some variation in actual services performed.
“When we do valuation modeling, we use a fees-for-services kind of approach – not paying for endorsements and certainly not for referrals. Continue to think in those terms,” Meyer said.
It is also a good practice to get attestation from the marketer and indicative data (screen prints, etc.) to demonstrate that the work is actually being done (and that you are paying for the services accordingly).
Irsch then discussed the more intricate components of Internet advertising (such as how to get the most traffic).
There’s more to consider than where your advertisement is going to be placed on the website (bottom, top, corner, banner, etc.), or how far one may have to scroll down to actually see your ad.
When deciding how to advertise on the Internet, ask yourself the following questions: Are you paying for an ad or a link? Is the advertisement framed (meaning that it will appear on every page of the website)? Or, is the advertisement served on a page-by-page basis? Is the advertisement included within a rotation with other companies? If so, how many other companies? Is the website that you are placing advertisements on adapted to mobile?
“You want to be where the consumer is going to be when you are looking at advertising on a website,” Irsch said. “Where is the consumer going to be on a real estate broker website? They are going to be on the [property] listing pages. Almost 80 percent of the traffic is on the listing pages and the property search pages.”
Although it might sound beneficial to have your own page (complete with a bio and contact information) on a broker or real estate agent’s website, Irsch warned that very little traffic will find its way to that page (in fact, usually less than 5 percent).
“Being on the home page is nice,” Irsch said. “You’re going to get 20 percent of the traffic through the home page. If they have a financing page, [you’re going to get] less than 10 percent. If they have a single page for you as a partner, you’re going to get almost no traffic on that site.”
Websites are just one thread in the web for placing advertisements. There are also options with social media (such as, Facebook, LinkedIn, Twitter, etc.) as well as intranet (sites that are often geared toward a specific group and/or require a login) and third-party platforms. Pin posts and videos also are becoming a popular means of advertising on the Internet.
One disadvantage with social media, however, is that you cannot control the commentary (such as from Internet trolls) that may take place about your products or services.
With specialized platforms, you may not be able to see the advertisement you’ve placed, unless you’ve been given a screen shot or login, or unless the advertisement is placed on the actual login page, which is a prime spot.
Another thing to consider with intranet and login platforms is the number of impressions you receive, as opposed to just the number of members. This is because, although a group may have a large number of members, those people might only log into the actual portal once or twice a month.
A final item Irsch discussed was lead generation.
When you are paying for an advertisement, ask yourself: What other functionality are you getting? Are you getting access to leads? If that is the case, how are those leads managed? Does the host company have a suite of tools that allow you to go after those leads in a compliant, structured manner?
Related Articles
Still on the fence about MSAs? Consider these alternatives
How can in-house counsel ensure a smooth CFPB exam?
Before offering that discount: Think of this
RESPRO Live: This is just round one of TRID changes