Kovo Affiliate Marketing Guidelines

HOW TO TALK ABOUT KOVO: “DO’S”

Kovo is a registered public benefit company that operates an online retail platform with products that help improve economic mobility. To comply with relevant laws and regulations, Kovo commits to providing fair, transparent and upfront information about all products, pricing and benefits. This commitment extends to Kovo’s partners as well.

  • Do provide all information about all fees and pricing prior to the customer entering into a commercial transaction.
  • Do date the marketing collateral.
  • Do ensure the proper disclosures are listed if there are trigger terms in the marketing collateral. See later section for details.
  • Do ensure any disclosures are in compliance with the four P’s. See Disclosure section for details.
  • Do ensure any Testimonials and Reviews used in marketing collateral are approved by Kovo. See later section for details.
  • Do ensure all marketing collateral is in compliance with UDAAP. See later section for details.
  • Do use the FTC Material Connection Disclosure on every article, in a clear and conspicuous manner: “Kovo may compensate us after you enter into a commercial transaction with Kovo using the links we provided.” See later section for details.
  • Do ensure collateral material is in compliance with regulations listed in the other material regulations section. See later section for details.

HOW TO TALK ABOUT KOVO: “DON'TS”

  • Do not guarantee that the customer’s credit score will increase.
  • Do not encourage customers to enter into a transaction that they cannot afford.
  • Do not say that Kovo is a way to build credit “without going into debt”.
  • Do not advertise a “price for score”.
  • Do not exhibit Kovo’s copyrighted material or Kovo’s marketing collateral without prior approval.
  • Do not redistribute your or other people’s communications with Kovo without prior approval, irrespective of whether these are in private or public forums.

ANSWERING QUESTIONS FROM CUSTOMERS

Affiliates must direct consumer questions to Kovo Support at support@kovocredit.com.

DISCLOSURES (4 P’s)

  1. Prominence – Disclosures must be clear, legible and noticeable. Collateral needs to disclose the fees, penalties, and other charges that may be imposed and the reason for the imposition.
  2. Presentation – Disclosure formatting must be easy to understand, in some cases consider illustrative examples.
  3. Placement – Disclosure needs to be obvious and in a place that the consumer will see it.
  4. Proximity – Disclosure needs to be close to the claim it qualifies in order to resonate in the mind of the consumer.

TESTIMONIALS & REVIEWS

If testimonials, endorsements or quotes are used, they must reflect the honest opinions, findings, beliefs or experience of the endorser or individual being quoted. Please request approved Testimonials and Reviews directly from Kovo.

UDAAP COMPLIANCE

Unfair, Deceptive or Abusive Acts and Practices (UDAAP) broadly covers advertising claims, marketing and promotional activities, sales practices in general, as well as the same activities in print, online, television, telephone, and radio. Partners should be cautious when marketing a program to ensure that no practice could be considered unfair, deceptive or abusive (includes bait-and-switch).

Unfair
  • Substantial customer injury, and
  • The injury cannot be avoided, and
  • Not outweighed by any benefits to the consumer or competition (consumer is powerless, lack of choice).
Deceptive
  • Representation, omission, or practice is likely to mislead,
  • Customer has acted reasonably,
  • Representation, omission or practice is material (likely to affect choice).
Abusive
  • Representation, omission, or practice is likely to mislead,
  • Customer has acted reasonably,
  • Representation, omission or practice is material (likely to affect choice).
UDAAP Risks
  • Complex features or terms,
  • Materials not in “plain” language,
  • Offering products to consumers/customers who do not understand financial concepts,
  • Promotional practices that create confusion,
  • “Steering” cardholders to expensive options

FTC MATERIAL CONNECTION DISCLOSURE

The Federal Trade Commission (FTC) requires that all paid affiliate relationships must be clearly and conspicuously disclosed.

The following disclosure should be used (unless an alternate version is approved by Kovo): “Kovo may compensate us after you enter into a commercial transaction with Kovo using the links we provided.”

The disclosure must be clear and conspicuous:

  • It must be close to the claims to which it relates (immediately before or after the Kovo post);
  • in at least 8 point font;
  • in a shade that stands out against the background; and
  • for video ads, on the screen long enough to be noticed, read, and understood.

This disclosure cannot be part of a catch-all disclosure. For example, “I receive compensation for some of the products I discuss on this site.” This disclosure cannot be contained in a hyperlink to a full-disclosure elsewhere on the site.

Social media guidelines:

  • YouTube: Disclosure must be stated/displayed at the beginning of the video. A listing in the description is not enough.
  • Instagram: Disclosure should be present in the first three lines before a user would have to click ‘more.’
  • Snapchat/Instagram Stories: Disclosure must be superimposed on image and conspicuous (i.e. font must be on a contrasting background & must be visible for a reasonable amount of time for your audience to understand the relationship)
  • Reasonable hashtags/disclosures for social media platforms with limited characters: paid ad, sponsored, promoted, ad:, #ad, #sponsored. No other alternatives are permitted. If you have questions, reference: https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking

OTHER MATERIAL REGULATIONS

  1. All e-mail messages must comply with the CAN-SPAM Act of 2003
  2. All SMS marketing must comply with the FCC 2012 TCPA Order
  3. All telephone marketing must comply with the Telephone Consumer Protection Act of 1991

Effective: April 29, 2022