Marketing AI agent · insider disclosure
Social and Community Management AI Agent
Instruct the reviewer before the review appears, and keep what was said: 16 CFR § 465.5(c)(1)(ii) makes failing to instruct an element of the violation, not a lapse in hygiene.
- Typical delivery
- 4–6 weeks
- Deployment
- Your stack
- Named owner
- Insider posts
- After launch
- Agent Care
What this agent does
Assembles the record, never publishes the post
In
- 01
A review appears, and 16 CFR Part 465, at 89 FR 68034, took effect on 21 October 2024.
- 02
A post is drafted by an employee, and § 255.5 counts the payslip as a material connection.
Reason
- 03
A review is written by an officer, and § 465.5(a) wants that relationship disclosed.
- 04
A review hub you control publishes, and § 465.6 asks whether it reads as independent.
- 05
An instruction goes unissued, and § 465.5(c)(1)(ii) makes that omission the violation.
Decide
- 06
An undisclosed review surfaces, and § 465.5(c)(1)(iii) turns on what you then remedied.
- 07
A takedown is proposed, and § 465.7 reads a groundless threat to a critic as the wrong.
Out
- 08
A post is archived, and no US rule makes an ordinary business keep it for a period.
- 09
Execute write actions only inside the approval boundaries agreed during implementation.
Product statement
The agent drafts and routes community replies, records the instruction given and the remediation taken, and flags. A named person publishes, discloses and decides a takedown.
Example workflow
One post, evidence to publication
- 1Post evidence receivedOwned-account posts, review feeds, community threads or moderation queues
- 2Post context assembledThe post, the account it sits on, the connection behind it and the day it appeared
- 3Disclosure evidence draftedThe post, its connection, the instruction issued and completeness
- 4Controls appliedConnection checks, disclosure checks, sentiment-neutrality checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is published at any of them — the agent is assembling, and the legal lane opens at the completeness gate.
Goes to the social owner to approve.
Adds a legal counsel read first.
Legal review
The post is held with its connection, its instruction and the account it sits on.
Publish · Append evidence · Send to legal review
Published — by a named owner
- 6Post and community records updatedOnly where write access and records policy allow it
- 7Outcome evaluatedDisclosure coverage, instruction records, reviewer corrections and what the read found
Corrections
Each legal correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required
8 items
- Publishing a post to an owned channel.
- Deciding that a disclosure is not owed.
- Deciding a takedown under § 465.7.
- Setting the incentive terms under § 465.4.
Automation boundary
Agent acts unaided
- ✓Hold each post beside the connection that sits behind the person.
- ✓Record the instruction to disclose and the date sent.
- ✓Draft the community reply and route it to the owner who.
- ✓Flag the undisclosed insider review before the display set moves.
Nothing is published or disclosed except by a named person, inside the agreed boundaries.
- Judging whether a relationship is already clear.
- Telling the Commission anything at all.
- Setting the moderation policy posts are held to.
- Changes to live posts, replies or review displays.
Example output
One post, annotated
Our influencer outreach and negotiation agent owns paid creator sourcing, vetting and negotiation, while paid inventory suitability belongs to our brand safety and suitability agent; this page claims neither, and works the channels you own and the people you employ.
Record entry · single post
Illustrative example- Post
- Staff review, § 465.5(b)
- Recorded as
- Insider connection found, disclosure instructed
- Connection
- Employee
- Evidence of record
- Instruction issued, 3 August 2026
- Confidence
- Held unpublished
- Held for
- The social owner, by name
As received
Taken from the account record and the workforce feed — it reaches as far as those sources do.
What the record holds
- Account record
- Instruction issued
- Remediation taken
Why no takedown here
Whether a critical review may come down is a § 465.7 call, not a model output.
What the score decides
Below the configured threshold a post picks up a legal read before the owner sees it.
Action
PublishAppend evidenceSend to legal reviewValue
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value lands
Value 01 – 04
Every post
From the account that carries it
Where the evidence is used
Those advertising pages sit agency-side and answer to a client who booked the media; this one answers to the brand functions that employ the reviewer.
An employee is an insider
Section 465.5 reaches officers, managers, employees, agents and immediate relatives, and § 465.1 reads officer as owners, executives and managing members, and relative as spouse, parent, child or sibling.
What was checked, and not found
The word agent is used across § 465.5 and carries no standalone definition in § 465.1, the literal text of § 465.5 and § 465.1 wants a clean pull from the eCFR before anything is quoted at length, no survey of state fake-review or insider-disclosure statutes was undertaken, and no court-docket search was performed.
Build an evidence trail
The post, the connection behind it and the person who disclosed it stay together.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Owned social accounts
- Publishing and scheduling tools
- Posts, replies and comment threads
Review estate
- Own-site reviews
- review platforms
- Review and testimonial records
Workforce and advocacy
- Workforce feed
- advocacy tooling
- Employee and relative connections
Agent
Social and community management
- Reads the posts
- Tests the connections
- Holds for the owner
Community and case systems
- Forum platform
- ticketing
- Moderation and instruction records
Observability & evaluation
- OpenTelemetry
- Langfuse
- Supported monitoring/evaluation sources
Integration availability depends on the client's existing systems and API access.
Agent controls
Six filters between the model and the owner
Six filters laid end to end, the last the least generous. Whatever passes is named in the map below.
L6 · Outermost — last line of defence
Inward → L1 · closest to the model
- L1 – L2
- Test whether a post may go out
- L3
- Puts the publication in a person's hands
- L4 – L5
- Keep the post and the connection behind it
- L6
- Falls back to draft-only when signals degrade
How Nestack evaluates it
Evaluate the whole assembly — not only the disclosure record that comes out.
Coverage runs the whole depth of the workflow, and every layer is cut by slice.
Surface — the record an investigator reads
- E1Final-output evaluationDid the record hold what the post actually carried?
- E2Step-level evaluationDid the agent read the right account, the right thread and the live connection?
- E3Tool evaluationDid it read and write the correct post record and the correct instruction?
- E4Confidence calibrationDo low-confidence posts actually attract more legal corrections?
- E5Slice evaluationHow does performance change across specific channel types?
- E6Business outcomeHow many posts needed a correction before the owner published?
Floor — the record the brand answers for
Failure modes
Where each failure originates in the agent
Seven failure modes, each set at the stage where it first shows.
Agent lifecycle
Direction of processing →
01 · Retrieval
1 mode
- LE-03
Stale thread read
The thread read is not the one now on display.
Stage gathers
The posts, the accounts, the people and threads
02 · Reasoning
2 modes
- LE-04
Disclosure asserted, not shown
A post is called clear with no connection check.
- LE-06
Reserved section worked as live
Review hijacking is worked as a Part 465 duty.
Stage proposes
The posts, their connections and completeness
03 · Tool / write
2 modes
- LE-02
Thin post passed forward
A post moves on without the legal read.
- LE-05
Bound to the wrong person
A connection is filed against the wrong account.
Stage writes
Only where write access and approval policy allow it
04 · Output
1 mode
- LE-01
Published, instruction unrecorded
The record shows a post but not what was instructed.
Stage returns
The record an owner clears and a reviewer reads
05 · Change / Version
1 mode
- LE-07
Silent moderation drift
A policy change biases removals, not the record.
Stage tracks
Model, prompt, disclosure rules and post fields
- Sev-1 · an insider review left undisclosed
- Sev-2 · a critical review cut on sentiment
- Sev-3 · source degrades, post held in draft
Affected slices
Employee posts absorb the corrections
A channel-level disclosure-coverage figure can read clean while employee and insider posts carry most of the rework. Nestack reports the correction rate by channel, not only in total.
Slice performance — reported separately, not only in aggregate
Illustrative example| Slice | Failure rate | Lift | Lift vs. threshold | Status |
|---|---|---|---|---|
| Employee and insider posts | 10.5% | 3.6× | Review | |
| Own-site review estate | 7.5% | 2.6× | Review | |
| Community forum threads | 4.6% | 1.6× | Watch | |
| Brand account replies | 2.1% | 0.7× | Normal |
Bar: correction-rate lift vs. brand-reply baseline · scale 0–4.0× · tick marks the 2.0× review threshold
2 of 4 slices over threshold
Evidence-linked improvement
What an undisclosed staff review costs
The loop shuts when the undisclosed staff review is a regression case. That suite is what the next post cleared is measured against.
Improvement cycle · five stages
Switchback — the path turns at Improve and returns at Learn
- 01
Detect
Correction rate rises on employee and insider posts.
- 02
Diagnose
The five-star review written by someone whose payslip the company signs is read back until one cause remains.
- 03
Improve
Any change goes out numbered, with the posts that caused it attached.
- 04
Verify
One post case still failing is enough to hold the release back.
- 05
Learn
One case joins the suite, one line joins the disclosure record.
Learn → Detect
The return edge. The next post is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, disclosure assembly, evaluation, integration, then production validation and handover.
Workstream
Week 1Week 2Week 3Week 4Week 5Week 6
- 01Insider-disclosure discovery and boundary work.Week 1
- 02Owned-channel and review-estate sources.Week 1, Week 2
- 03Post-to-connection and disclosure-coverage mapping.Week 1, Week 2
- 04Post and review ingestion.Week 2
- 05Post, connection and record binding.Week 2, Week 3
- 06Completeness scoring and review routing.Week 3
- 07Owner publication workflow.Week 3, Week 4
- 08Community-platform integration.Week 5
- 09Connection and instruction cases.Week 4, Week 5
- 10Guardrails and moderation controls.Week 4
- 11Post-trail instrumentation.Week 5, Week 6
- 12Deployment, documentation and Agent Care handover.Week 6
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel
Final scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
| Capability✓ in scope · — not at this tier | PilotOne channel, one year | ProductionProduction publication workflow | AdvancedMultiple brands / markets |
|---|---|---|---|
| Introduced at Pilot | |||
| Disclosure assembly to your channels | ✓ | ✓ | ✓ |
| Named owner publication | ✓ | ✓ | ✓ |
| Owned-channel baseline | ✓ | ✓ | ✓ |
| Introduced at Production | |||
| Reporting by channel | — | ✓ | ✓ |
| Publication workflow in your systems | — | ✓ | ✓ |
| Approved write-back | — | ✓ | ✓ |
| Community-platform integration | — | ✓ | ✓ |
| Introduced at Advanced | |||
| Multi-brand estates | — | — | ✓ |
| Cross-market evidence packs | — | — | ✓ |
| Large community estates | — | — | ✓ |
| Multi-account disclosure controls | — | — | ✓ |
| Build price | From $5,000 | From $8,000 | Custom quote |
- Final build price
- Confirmed after discovery based on integrations, workflow complexity, post volume, approval controls and deployment requirements.
- Separate from build
- Build pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bring
We build with it
01Your owned accounts and review estate
→Channel inventory mapping and post capture
Week 102Representative posts, reviews and community threads
→Record binding, disclosure logic and the coverage baseline
Week 203Your officers, managers, employees and their relatives
→Channel mapping, connection binding and the automation boundary
Week 104Access to relevant APIs, feeds or exports
→Channel, review and workforce-source assessment, then integration setup
Week 205Posts you would not want produced
→Disclosure cases and the failure-mode run
Week 406What no moderation log may prove
→Completeness scoring, review routing, guardrails and release controls
Week 307A named owner to publish the post
→Publication workflow, then pilot and production validation
Weeks 5–6
Nothing else is required
Deployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
What each bar spans is working time and not the drawn page, so a pair has to share the fifth week.
Phase
W1
W2
W3
W4
W5
W6
- DiscoveryW1
- BuildW2 – W3
- EvaluateW4 – W5
- Pilot & LaunchW5 – W6
Week focus
W1Social workflow discovery, channel mapping and the automation boundary
W2Source integration and the disclosure-coverage baseline
W3Disclosure assembly, connection logic and moderation controls
W4Evaluation suite, insider cases and failure-mode testing
W5Community integration, pilot posts and targeted corrections
W6One community year run under the social lead, then Agent Care handover
- Reading the band
- Each bar covers only the weeks its own work is named for. The fifth holds a pair because the work does.
- At the end of W6
- Once the disclosure record validates, Agent Care assumes the agent.
- Duration
- Six-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Marketing AI agent
Build a social agent around the review your own payroll wrote and nobody instructed to disclose.
One post, and the person standing behind it, is enough to begin. Show us your instruction record and the remediation that followed. Nothing under Part 465 or Part 255 is signed, filed or certified; both are conduct rules read after the fact.
- Typical delivery
- 4–6 weeks
- Deployment
- Your channels
- Named owner
- Insider posts
- After launch
- Agent Care available
Nestack Agents · insider disclosure
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