For the last few years we've made attemps to call out illegal, non-compliant, unethical, or offensive financial advertising. Originating mainly from pay-per-lead services, the plethora of deceptive finspam has left a permanent stain on the industry's underpants.We were fortunate to be asked to provide advice and guidance to various groups over the last year, and it's great to see Facebook implement many of the changes we've suggested. What they've introduced is a good start. It's not a fix, but it's another layer of protection for consumer.After we authored our final recommendation, we asked 72 lenders to endorse our prposals, and we were thrilled to receive 72 responses. Of the 41 aggregators we asked, none chose to endorse what was essentially a manifesto for ethical advertising.As far as Facebook is concerned, anybody running ads will have to validate themselves and their licencing. We've completed this with all our active clients, so this post is for everybody else.From Facebook:To help prevent fraud and impersonation in financial products or services advertising, and in some cases to comply with regulatory authorities, Meta may ask you to verify information about yourself or your organization in order to publish ads that promote financial products or services. These requirements are intended to promote consumer safety. Before running eligible financial services ads, advertisers will need to verify information about the ad beneficiary and payer, including their Australia Financial Services License information (unless otherwise exempt). Generally, the beneficiary is the individual or organization benefiting from the ad, whereas the payer is the individual or organization paying for the ad.Eligible financial services ads will need to contain a Paid for By disclaimer, featuring the name of the individual or organization paying for and/or benefitting from the ad. The clickable disclaimer leads to a separate info sheet. https://en-gb.facebook.com/business/help/719892839342050.. #beliefmedia #linkedincompany #linkedin #advertising #facebookmarketing #facebookadvertising #marketing [title: FB Verification Required For Financial Advertising]
I tend to waffle on about the lack of a comparison rate in advertising, and It's not because I think the comparison is overly important, and it's not simply because it's against the law. It's because I see it as a deliberate means to deceive consumers. Failure to abide by such an entry-level and seriously basic obligation - particularly when consumer-facing communication is intentionally crafted to trick customers - is a symptom of something much uglier. Brokers have evolved into the primary channel for obtaining a home loan, and this places a bigger-picture burden on the entire industry to hold itself to the highest of standards, and our honesty, integrity, and ethical behaviour is measured in binary terms - either we're honest or we're not, and when over 80% of all consumer advertising manufactured by brokers is manipulative or dishonest in some way, this ubiquitous malfeasance inevitably shapes consumer opinion and invariably impacts the credibility of those honest brokers that have higher standards.Sadly, the everyday infractions aren't limited to advertising. Most of the time, it's because brokers simply aren't provided with the necessary guidance.We've created a package for aggregators and ACL holders that deals with a number of compliance issues, and we've prepared a presentation suitable for PD days. If you'd like more information, please make contact with us.
About This Stock and Bond Business, by Louis H. Engel. The ad is so good that I'm sharing it 76 years after it was first written. Most copy we see nowadays is forgotten within seconds. There's so much to learn from this amazing ad and copy. Ogilvy was famous for his story telling, saying over and over that "the more you tell the more you sell", but the unfiltered, raw, informative, compelling, educational, and entertaining copy that was central to the early examples of long form has slowly devolved into long 'squeze-type' 'copy that says virtually nothing, provides no answers, and exists solely for the purpose of escalating 'manufactured' intent with little regard to the broader 'Lantern' attributes that are central to BM's own advertising models (Experience, Expertise, Authoritativeness, and Trust).We often draw upon a Simpson's line "you don't make friends with salad" to articulate the nature of the digital handshake at the top of funnel, and this ad tends to support this ideology. Content engages, while hyped sales copy does not. "About This Stock and Bond Business" was one of Louis H. Engel's most innovative advertisements. Considered one of the the one hundred most influential ads in North American history, the ad appeared in the fall of 1948, approximately two years after he had joined Merrill Lynch.The ad consisted of six thousand words of very small print squeezed onto a full-size newspaper page (the full-page broadsheet advertisement was the original landing page). The copy was informational and educational, and textbook dry in tone. There were no explicit references to the firm's own brokerage services in the entire text, but at the bottom right of the page was a small calling card (call-to-action) that identified Merrill Lynch as the sponsor and invited readers to request free reprints of the advert in pamphlet form.Once tested, responses exceeded three million, and those returns translated into millions of prospective customers.Use long form to tell a story - not to sell. The former achieves the latter. Full write-up in our FB group.
There are a few big-ticket compliance SNAFUs in this ad (the exclusion of the comparison being the most obvious), but usage of the Coat of Arms in a black and white ad designed to emulate a Government document is the focus of this rant.The use of the mark is regulated under federal law, and its use in any advertising is prohibited unless specific permission is granted (and it never is, particular when used in consumer-facing finance advertising, and certainly not on ad that is natively non-compliant or deceptive).Let's look at some of the laws relating to usage of the Coat of Arms.1. Crimes Act 1914 (Cth). Section 73: Prohibits the unauthorized use of the Australian Coat of Arms in a way that suggests a connection to the Australian Government.2. Trade Marks Act 1995 (Cth). Section 39: States that the Australian Coat of Arms is a protected symbol and cannot be used in trade or commerce without authorisation. Use in advertising is considered a form of trade or commerce.3. Intellectual Property Laws Amendment Act 2015 (Cth). This amendment strengthens protections for official government symbols, including the Australian Coat of Arms.4. Copyright Act 1968 (Cth). The Australian Coat of Arms is not covered by copyright but is protected under laws governing national symbols. Misuse could still lead to enforcement under this act in conjunction with other legislation.5. Australian Government Branding Guidelines. These guidelines clarify appropriate uses of the Australian Coat of Arms and explicitly prohibit its use for commercial purposes, including advertising.6. Consumer Law. Implying a government endorsement or affiliation is misleading and a breach of Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010, Section 18).7. Other consumer/financial legislation deals with trickery, deception, false representation, false endorsements or associations, and consumer perception.Be careful.
"How to create financial advertising that sells" was a 1974 advertisement from New York based advertising agency Ogilvy & Mather. It's a master-class in copy.[More information and a full transcript of this advert can be found in our FB group]The 'financial advertising' advert was one of a number of Ogilvy's long-form advertisements that were used as a means of demonstrating their expertise and providing industry-specific social proof. The long-form advertising was a technique widely avoided by many in the fear that they were "giving too much away" (a ridiculous proposition when measured against our current understanding), but the technique was a defining feature of Ogilvy's ads while others were trying to be cute.Of interest is Ogilvy's line "the more you tell, the more you sell" (top right). While Dr Charles Edwards might have said it first, Ogilvy made it famous. There's no question that long-copy sells if you're selling the right product in the right way (sadly, something brokers just do not do).When Ogilvy and Mather printed the article they essentially took ownership of the principles discussed despite the fact they were commonly applied by others at the time (their points of diff were shared by others, but Ogilvy were the ones talking about them). Ogilvy took the long-form approach when others were printing small ads that weren't nearly as readable or compelling.If you write long form, tell a story. Stories master.
The relevance of the screenshot is because it was taken when our broker attracted 50 leads - the typical number of 'leads' delivered by leadgen charlatans at a cost of around 8k.Leads delivered by leadgen crooks convert under 3%, and usually closer to zero. You would literally enjoy more success if you parked your ass at a bus stop and talked to strangers. Let's say that our broker invested 8k into their *own* marketing using the above campaign (about 4X what most brokers will spend). That's 1221 leads.Funnel branded leads convert between 18% and 30%, with refinance campaigns usually coverting up to 28%.Let's say we converted just 25% of our 1221 leads with commissions at $3500. That's roughly 305 deals.The net result: $1,068,375.The guy that purchased 50 leads probably closed one deal and wasted a lot of time chasing ghosts. The reality? FB is slow initially with conversions around 20%. Even if you converted half of what we've detailed above you're still looking at $535k. Screw the pooch completely and you'll only walk away with $267k. On the flip side, you can always do better. Facebook advertising is not just interruption marketing - you're also competing with others using the same words... and most homeowners already have a broker (so it's literally relationship destroying marketing).We often say Facebook advertising is like hanging out at a Caltex service station expecting to meet classy girls. It doesn't happen.Around 90% of our time is spent helping brokers build their network. This month our partner program alone will return 560m. Our brokers will still advertise on Facebook, but it'll be for the same reason McDonald’s sells cookies.Not a single one of our current clients running FB ads is paying more than $70 for a conversion into a settlement. Not one.Invested in the 'Broker Grow'? - nothing to do with our awesome 'Broker Growth' program. Migrate across to our product, and if we don't improve your conversions by 300% overnight we'll give you 10k.
Commbank to charge $3 for cash withdrawals. Appaling.
Shad of the Day, 15th November 2024. More of the same nonsense with *multiple* compliance issues. This gem comes to us from 'Finance Group AU' (aka 'Finance Scanner' among other fake brokerage brands), and it's operated by a typical leadgen crowd called Biz Focused. If you're ever in need of some finance humour you simply need to sit yourself down and check them out... unless you're buying their leads, in which case you'll probably want a Bex and a sulky nap.I get tired of the Shad because it's the same recycled nonsense, but in this case it's worth mentioning because of the lengths these clowns go to in order to hide their involvement with the service (no mention on the website, no domain info etc). It makes me wonder if they're hiding from regulators, or perhaps they're creating distance so brokers don't connect the dots and identify the dodgyness (reminds me of the story of a guy that married a beautiful girl, only to learn on their wedding night that he had in fact married a feminine man). Either way, the pictured experience probably delivers leads to brokers at around $130, but if you did it yourself (a solid 10-minutes worth of work for something so simple), higher quality leads would be delivered for less than $10. We work in a crazy industry.Don't buy leads. The industry deserves better. Our customers deserve better.Stop the finspam.
At the risk of sounding like a broken record, I feel like I need to point out the obvious.Far too many legitimate businesses are exposing themselves to a litigious future, and excluding a comparison rate is the most obvious obligation imposed on our ads. If I were to consider quantitative claims, about every broker advert currently showing is illegal.... yet aggregation/ACL holders do nothing. I just don't get it.I've just published an article on a group called 'Broker Grow' showing some of the most egregious infractions I've ever seen (no relationship to our 'Broker Growth' program in any way). The article was necessary so brokers knew we had nothing to do with the lower-performing product.To recap. RG178.23"An advertised comparison rate must be identified as a comparison rate and the comparison rate must not be less prominent in an advertisement than any interest rate or the amount of any repayment stated in the advertisement: s164, National Credit Code.We [ASIC] consider that the following examples would result in the comparison rate being less prominent than the advertised interest rate:(a) a comparison rate is smaller in size or faded in colour when compared to the interest rate; or(b) an interest rate is published online and a consumer is required to click through or additionally do something (such as move their cursor over the interest rate) to view the comparison rate; or(c) the displayed comparison rate is not in close proximity to the displayed interest rate."RG178/RG234.156"It is not necessary to show that consumers have actually been misled - the law prohibits conduct that is *likely* to mislead.Consumers cannot be expected to study or revisit an advertisement - the most important consideration is the overall impression created by the advertisement when viewed for the first time. Silence can be misleading or deceptive when it is reasonable for a consumer to expect disclosure of important information - silence on important details can render a statement misleading, even though it is factually correct."It's not hard to be compliant.
Had the pleasure of Peter (from 'Duck Duck Go') and his family at the farm today. Currently Duck's product manager, he's previously worked with Firefox, Blackberry, and others. As far as I'm concerned, his greatest claim to fame is work as the Technical Adviser for the series finale of HBO's 'Silicon Valley'. A true genius. Looking forward to next time.
Shad of the Day, 7th November 2024. Just another example of somebody using trickery to bait consumers into a phone call (by failing to disclose a comparison). Note the second comment. The subscription experience celebrates the same commitment to compliance and ethical marketing. It's probably unfair to point this group out since non-compliance is now the rule rather than the exception.
Pictured are some recent domain name sales, although the big-ticket sales are normally protected by an NDA. The purchasers of these names understood the value of online real estate.I'm selling the website and leadgen facility behind what I believe to be the best domain in the industy. It comes with trust, appeal, socials, and traffic. You'll take ownership of a massive and diverse segment of the population (as I once did), you'll attract significant organic traffic, and you'll promote with authority.Call me on 0400 777 300.police.com.au
