Compliance managers at credit card issuers, networks, and publishers have the unenviable task of keeping their programs compliant in a constantly changing space. Every time a credit card issuer changes a rate, for example, there is a risk that webpages across the ecosystem of content housed on the web, will be out-of-date. The risk for non-compliance is high and the consequences range from frustrated or misinformed customers to fines and legal action taken by regulatory agencies. Every word published—by the issuer, by a partner, by an affiliate, or even by a consumer—creates an opportunity for risk.
This is why we’ve compiled a list of 11 best practices for keeping your credit card marketing program compliant. This is by no means an exhaustive list, but a good start to minimizing your risk.
1. Regularly review pages that include card offers.
Whether you keep track of all the pages that promote card offers through an Excel spreadsheet or use an automated web compliance tool like BrandVerity’s, it is a best practice to monitor and regularly review all of these pages. Regular review ensures that you catch changes to pages that might affect the card offer. In an ideal world, you are able to identify and review changes to those pages as soon as they happen. Regular review should be in addition to the reviews you do right after a rate or offer changes.
2. Audit the links used in card offers.
Identify the links that your content and your partners' content pages are using and check that they take consumers to the correct application page. Consumers can easily be confused by an offer that promotes one card but links to an old version of that offer or a different card altogether.
3. Monitor content on removed publisher sites.
Promotional relationships change for lots of reasons. Verify that the publisher modifies their site to reflect those changes. It might be as simple as removing an affiliate link, or you may want to check that the card is no longer featured in marketplaces. You may even have to ask that the card be removed entirely.
4. Ensure credit score restrictions are enforced.
As you introduce products targeted at particular credit segments, make sure that your partners are marketing those cards to the appropriate segments. A card intended for high credit score consumers shouldn’t be marketed to consumers with lower credit scores. It is important to prevent credit cards with those restrictions from appearing in the wrong brackets.
5. Make sure that editorial content includes clear disclosures on expired offers.
Editorial content can be a big pain point for compliance managers; there is a lot of it and much of it often discusses expired offers. While we’ve seen issuers take a number of different approaches to managing outdated content, the guiding principle is to ensure consumers don’t confuse an expired offer for a current one. We usually guide issuers to take a number of steps to minimize this risk of misinformation: First off, ensure that the content contains a clear and conspicuous date so that older blog posts can be kept in context. Second, all affiliate links should either be removed or redirected to a page stating that the offer is no longer valid. Finally, expired content should be updated to include a clear statement that the offer is no longer available. The placement of this disclosure needs to be in close proximity to the discussion of the card itself.
6. Spend time discovering new pages and websites.
Finding all of the pages that promote a card offer can be an incredibly challenging task. You’ll certainly be aware of many of the primary pages on a publisher’s website, but that content is often repurposed and displayed in other formats either on the publisher’s own site(s) or on those of their partners. In addition to the pages you are aware of that need to be updated when a rate or offer changes, there are many pages that have information regarding your credit cards that you may not be tracking. In particular, editorial content created by a blogger or an affiliate may not be on your radar screen. This is where an automated web compliance tool, that crawls large numbers of pages within seconds, can be especially helpful.
7. Prioritize top risks.
Once you start using an automated tool for the discovery of new pages that include outdated or incorrect information, you need to prioritize which ones require immediate action. An automated compliance tool can quickly identify thousands of pages requiring attention, but it can be challenging to sort and categorize so many potential violations. With an automated tool, you can filter or set parameters to flag the most dangerous or high-impact violations.
8. Communicate with your team.
It is important to have a system in place for recording the work and communication within your team. Keeping a record minimizes duplication of work and makes it easy to find the status of each issue. Has someone on your team already reached out to address a page with incorrect information? Has anyone confirmed that the page was taken down? When a rate change occurred, when and who checked that all the known pages were updated? These are the types of questions that can be difficult to keep track of if you are responsible for the compliance of a large-scale program.
9. Build an airtight process around card updates.
As you update your card offers, you’ll want to ensure quick and comprehensive updates not only on your own website but throughout your partners’ websites as well. Check that you have captured screenshots of all pages with an offer prior to an update and then capture new screenshots during and after the update cycle to ensure that all pages update properly and promptly.
10. Keep an audit trail.
It is virtually impossible to catch every potential error on the vast internet. Luckily, regulatory bodies don’t require perfection, but rather proof of a good faith effort to ensuring compliance. An audit trail–showing what actions were taken and when–helps document your process. If you are conducting your compliance manually, make sure all screenshots and emails are saved and organized in a way that is easily searchable. An advantage of using an automated tool is that it will store all the necessary documentation, making it audit-ready for the future if the need arises.
11. Monitor mobile versions of web pages.
Even when publishers build mobile-specific versions of their websites or responsive websites, it can be difficult to anticipate how content might appear differently on a mobile device. For example, disclosures that are clear and conspicuous on a desktop browser might not appear close to an offer on a smaller screen.
Whether you are an issuer, network, or publisher in the credit card space, keeping your credit card program compliant and ensuring a smooth customer experience, can be a bit overwhelming. Hopefully, this post will help you design a review and remediation process that works for you and your team. Most importantly, never lose sight of the customer. Leading compliance programs focus on the needs of the customer, proactively correct errors, and stay up to date on regulatory changes.