A Mortgage Marketers Guide to TikTok Compliance

One of the most vital components of online marketing – or any marketing - is that you are targeting the types of people that you hope will ultimately become your customers. Over the past decade, influencer marketing initiatives on platforms like Instagram and TikTok have become a key part of company marketing mixes for businesses eager to reach younger demographics. For TikTok marketers, these campaigns revolve around influencers creating and sharing videos that will in some way promote a specific business to their followers in exchange for payment or discounted services. This has proven to be especially effective in the past few years, but in highly regulated industries, the greater the reward, the greater the risk.  Visit www.tiktok.com to create an account. 

To avoid risks and reap benefits on TikTok, there are a few things to keep in mind. 

What is TikTok? 

TikTok is a popular social media app that allows users to create, watch, and share short videos shot primarily on users’ smartphones. When the app was first launched, TikTok videos were capped at one minute, but now can be up to 3 minutes long. With its personalized feeds of quirky, easily digestible content set to trending music and sound effects, the app is notable for its addictive quality and high levels of engagement. Amateur and professional creators alike can add effects like filters, background music, and stickers to their videos, and can easily collaborate with other creators from all over the world. 

Understanding the Account Types 

On TikTok, users can select to have a Personal Account or a Business Account, though most users use Personal Accounts. This type of account is a good choice for general TikTok users, content creators, and most public figures. These account types are a good choice for those who want to watch and interact with other people’s content or create their own content for others to enjoy. Business Accounts are public profiles that allow brands and businesses to use marketing tools to build a cohesive marketing strategy on TikTok. They're a good choice for anyone whose primary goal on TikTok is to promote their business (either products or services).  

For loan officers interested in promoting their services on TikTok, a Business Account is the ideal choice for multiple reasons. With a Business Account, users have access to advanced business tools that Personal Accounts do not, like:  

• Ability to add an email address to the TikTok profile 
• Access to pre-cleared sounds through the Commercial Music Library 
• Key analytics around content engagement  
• Advertising tools through Promotion
• Access to the Business Creative Hub to build content strategies 

Tools like this help businesses create a comprehensive marketing strategy. For those not willing to give up the personal TikTok they have already invested time in, have no fear – the TikTok Business Account is simply a setting toggle option. See TikTok’s Business Account Center for more information on how to make the best use of a Business Account.   

How do I Switch to a Business Account? 

Switching to a Business Account on TikTok is a fairly easy process. To switch your account type, follow the below steps when on your mobile device: 

1. In the TikTok app, tap Profile at the bottom.
2. Tap the Menu button at the top.
3. Tap Settings and privacy. 
4. Tap Manage account. 
5. Tap Switch to Business Account and follow the instructions provided to finish. 

Profile Compliance with a Limited Bio 

There are generally two categories for social media platforms: 

• Limited-bio social media - social media profiles that have a smaller character allotment than other social media platforms. Character counts for Limited-bio social media are generally limited to 100-160 characters. Examples of Limited-bio social media would include Twitter ("X"), Instagram, Threads, and TikTok.
• Full-bio social media - social media platforms that allocate larger amounts of characters for the About/bio section on a profile. Character counts for Full-bio social media are generally those with more than 100 characters. Examples of Full-bio social media would include Facebook, YouTube, Zillow, etc. 

It can be difficult to comply with all federal and state-by-state licensing disclosure guidelines on Limited-bio social media given the character count restrictions. As a best practice, key information should be included on Limited-bio social media accounts in the About/Bio sections, and other relevant disclosures should be included on individual advertisements themselves and one click away with a website link. The following fields are available for use for TikTok Business Accounts: 

• Username: Allotment of 24 characters in this field. Usernames can contain only letters, numbers, underscores, and periods. Changing a username will also change the profile link – i.e. www.tiktok.com/JeffLoanOfficer . Can only be changed once every 30 days. 
• Name: Allotment of 30 characters in this field. Also known as a “nickname”. Users may include their legal name as it appears in NMLS and their individual NMLS ID to meet SAFE act requirements. This can only be changed once every 7 days. 
• Bio: Allotment of 80 characters in this field. Users may use this field to include key information, such as company name, company NMLS, and equal housing information.  
• Email Address: To incorporate an email address field onto the profile, users must first ensure the account is a Business Account through the mobile app on their phone. 
• Website Link: this field becomes available when the account either gains 1,000+ followers or becomes a Registered Business Account. 

• Business Phone Number: this field becomes available when the account either gains 1,000+ followers or becomes a Registered Business Account.  

Registered Business Accounts 

TikTok currently offers a Business Registration option to incorporate a clickable website link on the profile. The Business Registration process will require various pieces of information & documentation be submitted, including but not limited to legal business name, country, address, business license ID, website, DUNS code, etc. Subsequent review of the application and approval by TikTok will grant access to additional business information fields, such as a business phone number or website. 

Understanding Post Content 

TikTok has become a go-to source for creating or watching short-form videos, but just because this concept is simple does not mean the app is simple to use. Each piece of content posted allows for up to 4,000 (previously 2,200) characters of text to be included. With this much room, it’s easy to add any relevant disclosures and licensing information based on the content within the video advertisement.

Some users have considered including key disclosures in a script for video content. Scripting disclosures on social media can be problematic for a few reasons, including:

• It may prove difficult for the consumer to hear the full disclosure, especially if music is overlayed on the video.
• If the consumer has a hearing impediment, they may not privy to the disclosure unless closed captions are utilized. Conversely, if a disclosure is included in the text content of the post, a screen-reader could be utilized. 
• Marketers and sales teams may be reluctant to read disclosures out loud and/or may read disclosures inaccurately. 

The good part? TikTok offers additional features that other social media platforms do not. TikTok is known in part for its ability to add text overlays to captured video content – this can be a simple way to include information like calls-to-action for a company website licensing page. TikTok is also one of the most ADA-compliant social media platforms out there with the ability to generate closed captions on a creator’s video content in real-time. Closed captions can be generated for multiple languages, including English, Spanish, and French, for those licensees or institutions who have dedicated resources towards LEP initiatives. 

Common Pitfalls 

TikTok is certainly one of the fastest-rising platforms of use within the mortgage industry, with many loan officer influencers having 6-digit followings. Videos with the #mortgageadvice hashtag on TikTok have been viewed over 47 million times, as cutting-edge mortgage professionals have begun reaching out with largely unsolicited advice to this vast and untapped generation of future customers. But while TikTok does have vast potential for a loan officer or other mortgage professional to build a reputation as a go-to educational source, it can also be a minefield of regulatory pitfalls. While short pieces of video content are easy for consumers to digest, it’s difficult to ensure that they include all the necessary information and disclosures for consumers to have a full picture of the offerings. In addition, TikTok video recordings are improvised with no script for compliance and marketing teams to review ahead of time. Additionally, with limitations on the profile bio section, it can be difficult to achieve state-by-state disclosure requirements for licensees who carry multiple state licenses.  

Our advice? Proceed with caution and partner with compliance and marketing teams to feel confident that TikTok will not pose an issue on the company’s next regulatory examination. See our article TikTok - The Newest Platform With Compliance Concerns for more insight.