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American National Insurance Company

Agent Social Media Guidelines 2011

Agent Social Media Guidelines

American National Insurance Company and its subsidiaries have recently adopted Agent Social Media Guidelines. This training course is an overview of the Guidelines and is designed to help you understand your obligations. You mustread the complete Agent Social Media Guidelines.


These “Guidelines” apply to all agents of American National Insurance Company and its subsidiaries, as well as the employees of such agents.


These Guidelines apply to all electronic communications that reference the Company through social networking websites such as:

Facebook LinkedInMySpace YouTubeblogs personal websiteswikis discussion

forums/chat rooms


The absence or lack of reference to a specific site or platform does not limit the scope of these Guidelines. As new sites and platforms emerge, the Company may amend these Guidelines as deemed appropriate.


Categories of posts:

• Advertising and Sales Literature

• Static Posts that constitutes advertising

• Static Posts that is not advertising

• Real-Time Posts


Communications that are designed to create public interest in the Company, its products, services, producers, or to encourage the public to purchase an insurance product are considered advertising and must be reviewed.

Any information relating to the Company or its products communicated by an agent for the purpose of recruiting representatives is also considered advertising.


All Social Media posts that are “advertising” must be pre-approved following the Company’s General Marketing Approval Procedures and Guidelines.

Using unapproved advertising, through Social Media or other media, may be a violation of state or federal regulations and corporate guidelines and may be considered a breach of your agent contract.


The Federal Trade Commission (FTC) has issued guidelines for advertisers using Social Media. The purpose of theses guidelines is to protect consumers from misleading, confusing or false information about products marketed in Social Media forums.


Examples of common violations provided by the FTC include:

• Paying internet users to post misleading reviews about a product or company.

• Creating fake blogs that appear to be objective but are really designed to promote a product.

• Posting misleading or false information by pretending to be an unaffiliated consumer.


Your Social Media activities, including insurance advertising, must provide disclosures stating:

• The name and home office address of the insurer(s) you represent.

• The states in which you are licensed. (if licensed in California, your license number)


Content that can be viewed for an extended period of time by many people are referred to as “static posts”.

“Static posts” include your profile, background and “wall” information posted on Social Media.


Examples of “real-time electronic interactive communication”

• Chat room participation

• Group discussion forums

• Online seminars

• Interactive blogs

• Wall posts and other posts


“Real-time electronic interactive communications”are similar to a public appearance and may involve unscripted communications. Transcripts or detailed accounts of the communication must be provided to your Marketing division.


When engaging in “real-time electronic interactive communications” as part of your business, you must follow:

• Agent Social Media Guidelines

• Privacy and Information Security policies

• General Marketing Approval Procedures and Guidelines.

• All other Company policies and procedures applicable to your agent agreement with the Company.

Agent Social Media GuidelinesOn Social Media you should not:

• Address coverage or claim questions from customers or potential customers

• Provide specific product advice or recommendations

• Seek nonpublic personal information about a customer or potential customer in a public forum such as Social Media.

You must conduct such business discussions privately, in person, by telephone or secure (encrypted) email.


On Social Media you should not:

• Reference or cite Company clients or customers.

• Handle complaints through your Social Media postings.

• Use Company logos and trademarks without the Company’s written consent.


With any use of the names of American National Insurance Company or any of its subsidiaries, even in your personal use of Social Media, you must identify your name and your relationship with the Company. For example you may not imply that you are the “owner” of American National Insurance Company or any of its subsidiaries.

You must not misrepresent yourself. Make it clear that you are speaking for yourself and not on behalf of the Company, even if you casually reference the Company.


You may not maintain a Social Media page under the name of American National Insurance Company or any of its subsidiaries, or under any abbreviated name of any such companies such as ANICO, ANPAC or Farm Family. Such names are the property of the Company.


• You may not request any designations such as “like”, “fan”, “recommended” or similar designations posted on Social Media from others in connection with your insurance business activities. Such designations could be considered testimonials by regulators.

• You may not “like” or “recommend” statements made by customers or other third parties on your Social Media site, as these designations could be construed as endorsements of the statements made by regulators.


You are personally responsible for the content you publish on Social Media. Use good judgment about what you post, as it will be public for a long time and could be seen by a large number of people. Remember that anything you post reflects on yourself and possibly the Company.


• Never disclose any non-public financial or operational information about the Company. This includes, but not limited to, strategies, forecasts, and any other financial or operational information.

• Do not provide the Company’s or another’s confidential or proprietary information. The Company’s privacy policies apply fully to the use of Social Media.


• Do not post derogatory or offensive statements about the Company, its competitors, its customers, employees or other agents.

• Never post anything to do with a legal case, regulatory matter, or communications with attorneys representing the Company.


• Adhere to all copyright, fair use, and financial disclosure laws, and reference or cite source appropriately.

• If you identify yourself as an agent of the Company, ensure your profile and related content is consistent with how you wish to present yourself to potential customers and colleagues.

Agent Social Media GuidelinesIf the name or trademarks of American National Insurance Company or any of its subsidiaries, or other information relating to your service as a Company agent appear on your Social Media posts, including any personal Social Media sites, you must provide the following disclaimer:

“The postings on this site are my own and do not necessarily represent the positions, strategies or opinions of the American National Family of Companies.”


If you maintain a Social Media site for your insurance business, you must also include the following disclaimer:

“Neither I nor the American National Family of Companies are responsible for statements posted by third parties. All logos and trademarks are the property of their respective owners”.


Variable Life, Variable Annuities and Other Securities Products

You may use Social Media in connection with the marketing of variable insurance products or other securities products only if permitted by your broker-dealer firm. This restriction includes any “profile” or ”static” posts, and “real-time electronic interactive communications” that reference securities products in any way.


Variable Life, Variable Annuities and Other Securities Products

Even if your broker-dealer permits certain Social Media activity in connection with the sale of variable insurance products issued by the Company, you must still comply with these Guidelines and the Company’s General Marketing Approval Procedures and Guidelines.


Company procedures and control processes that may be applicable to Social Media:

• Advertising and Marketing Materials Review Process (pre-use approval) See Examples of Social Media Posts Requiring Prior Approvals

• Supervisory Review of Communication

• Use of Testimonials (i.e., you may not post testimonials of customers or other third parties commending your services or Company products without complying with Company policies on testimonials)


• Correspondence Review Process (post-use review in connection with customer complaints, regulatory or litigation issues)

• Complaint Handling

• The Handling of Third Party Posts (i.e., the use of the Company name by third parties)


The Company reserves the right to conduct reviews of Social Media use. Violation of these Social Media Guidelines may be considered a breach of your agent contract.


If you engage in Social Media activities using Company owned computers, cell phones or other devices, you should have no expectation of privacy in any message, files, data, pictures, conversation, or other posts, on the Company’s electronic and communication systems.

Agent Social Media GuidelinesPosts that Require Prior Approval

• “Call me today for a quote on your life insurance needs.”

• “American National Insurance Company offers a number of fixed annuities for your retirement needs.”

• “Looking to save some money? You may be paying too much for your car insurance.”

• “Have you reviewed your family’s insurance coverage lately?”

• “Interested in a career change? Call me to learn about becoming an American National Insurance Company agent.”


Posts that DO NOT Require Prior Approval

“Happy Birthday, Mom.”

“Go Central High Spartans! Beat those Cougars!”

Congratulations to our local high school and college graduates!”

Looking forward to vacation! I’ll be out of the office next week.”


Real-Time Discussions

Real-time discussions conducted via Social Media with friends, customers or potential customers are generally not considered advertising.

However, discussions that include specific product information, pricing or the solicitation of a product should be conducted offline.


Real Time Discussion Example:

The exchange on the next slide could be conducted by the agent without prior approval.

However, if the agent began discussing specific products, the exchange would require prior approval.


Potential Customer: “I’m thinking of buying a whole life policy. Does American National offer whole life?”

Agent: “Yes, I would be happy to talk to you about your needs.”

Potential Customer: “How much would $250,000 coverage cost?”

Agent: “Please call me today anytime after 1:00. I believe we can find a product for your budget.”


Apart from these Guidelines, which apply to you as well as your employees, the Company urges you to evaluate your risk as it relates to Social Media. This may vary depending on the unique considerations of your business plan. However, please consider these:

• Develop a Social Media policy for your business.

• Designate a Social Media point person.

• Understand and adhere to the FTC guidelines.

• Review and understand your applicable commercial insurance coverage regarding advertising.

Agent Social Media GuidelinesResources

• FTC Guides Concerning the Use of Endorsements and Testimonial in Advertising

• General Marketing Approval Procedures and Guidelines

• Management Information Security Policy and Guidelines

• Guidelines for Sending Electronic Communications to the Public

• Complaint Handling Process

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