We have known for decades that word of mouth from a trusted source is the most valuable media channel in the marketing mix. A brand endorsement can come from a host of sources: someone we personally know, the collective reviews of other customers, key opinion leaders who post online about subjects we care about, celebrities whom we admire and/or the media themselves. All these different forms of word of mouth are extremely valuable for a key reason: consumers believe the word of others before they will believe the word of the marketers. That’s why “earned” media has always been more valuable than “paid” media.
The operative word is “earned.” An endorsement from a trusted source (whether it’s an individual customer, a blogger, a ‘celebrity’ or a respected media outlet) must be earned. It cannot be paid for. If it’s paid for, it’s an ad. And, even worse, it’s a deceptive ad if it isn’t clearly labeled as such. Currently, the FTC guidelines for paid Influencer endorsements on social media, such as Instagram, are fairly lax. As long as a social media post has a hashtag that calls out the post as #sponsored, #partner, or #ad, etc. the post is compliant.
Unfortunately, unlike labeling guidelines for other forms of advertising that mandate clear and prominent labeling of “sponsored content”, there are no requirements to-date that make a #sponsored or #ad hashtag stand apart from the litany of hashtags that are usually associated with a social media post. The end result: the follower is left to figure out for themselves whether the Influencer is being genuine in their endorsement or whether they are being paid for it.
To make matters worse, if you take a random audit of any lower tier celebrity’s Instagram pages you will be shocked (maybe not) at the degree to which these Influencers do not comply with FTC guidelines. I am not trying to pass judgment on these celebrities for calling them “lower tier”; rather, I am using the label to identify a significant portion who do not have management teams who are responsible for the social media accounts of their clients. I would hope that a publicist and their team would keep their client’s endorsements compliant with FTC guidelines.
Since I am not a fan (at all) of ABC’s “ Bachelor” franchises I decided to take a look at how some of their cast members (I use the term loosely and with a heavy dose of sarcasm) are faring when it comes to being compliant with their Instagram sponsored posts. While this sample isn’t representative by any means, it’s quite disconcerting that a random sweep through the Instagram accounts of members of the Bachelor Nation on a Saturday afternoon yielded so many violations. Here is an example of how one cast member from the Bachelor Nation promoted National Coffee Day:
To be fair to this young celebrity, another post on her Instagram literally just a few pictures away does comply with FTC labeling guidelines (see below). This raises the question: who is creating these ads—oops, I mean posts? What measures are in place to ensure consistency in labeling and overall compliance? Who is ultimately responsible for misleading consumers? The celebrity? The marketer? Or both?
Marketers are only kidding themselves if they truly believe that audiences are not seeing through these tactics for what they really are— bad ads! Just read some of the feedback that a celebrity’s followers leave beneath these sponsored posts: it won’t make you warm and fuzzy, that’s for sure! In several instances the follower will call out his/her celebrity idol for “selling out” and “selling ads.” And, then the fan zealots who are called “army’s” will, in turn, attack the follower who is throwing shade at their idol. Meanwhile, the marketer is wrongfully thinking that they just created a wonderful endorsement for their product. We talk about questionable advertising environments. When was the last time a marketer checked out the pollution that flows freely on these Instagram accounts? Is there any resulting damage to the brand being promoted? Only time will tell.
How pervasive is this phenomenon? I applaud a fellow cast member of The Bachelor Nation for poking fun at his comrades (and at us) with this tongue-in-cheek post promoting “The Bachelor Budget Edition” of what he calls the “#dullfatlame fall crate. Good for him (see below)!
Who is really to blame? Is it the owner of the Instagram account who is trying to make a few bucks? Is it the FTC for not cracking down on non-compliance? Or, is it the marketers, themselves? Marketers know better! It shouldn’t take regulations and compliance to keep marketers from doing what they know is wrong in the first place. Paying for an “influencer” is an oxymoron. Earned media must be “earned.” If marketers do not abandon the practice of paid influencer marketing they run the risk of destroying the most valuable media channel that we have. And that would be quite a shame.