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

  1. 01

    A review appears, and 16 CFR Part 465, at 89 FR 68034, took effect on 21 October 2024.

  2. 02

    A post is drafted by an employee, and § 255.5 counts the payslip as a material connection.

Reason

  1. 03

    A review is written by an officer, and § 465.5(a) wants that relationship disclosed.

  2. 04

    A review hub you control publishes, and § 465.6 asks whether it reads as independent.

  3. 05

    An instruction goes unissued, and § 465.5(c)(1)(ii) makes that omission the violation.

Decide

  1. 06

    An undisclosed review surfaces, and § 465.5(c)(1)(iii) turns on what you then remedied.

  2. 07

    A takedown is proposed, and § 465.7 reads a groundless threat to a critic as the wrong.

Out

  1. 08

    A post is archived, and no US rule makes an ordinary business keep it for a period.

  2. 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

  1. 1Post evidence receivedOwned-account posts, review feeds, community threads or moderation queues
  2. 2Post context assembledThe post, the account it sits on, the connection behind it and the day it appeared
  3. 3Disclosure evidence draftedThe post, its connection, the instruction issued and completeness
  4. 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.

5DecisionSplits at the completeness gate
Evidence sufficient

Goes to the social owner to approve.

Anything thin

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

  1. 6Post and community records updatedOnly where write access and records policy allow it
  2. 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 review

Value

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

03Evidence

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.

01Approved path

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.

02Human review

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.

04

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

L6Rollback / safe modeNarrow the agent to evidence assembly when evaluation or production signals degrade.Roll back
L5Version monitoringTrack model, prompt and disclosure rules; § 465.3 stands reserved after the Notice of Informal Hearing of 16 January 2024, so nothing here answers review hijacking.Track
L4TraceabilityRecord each post, the connection behind it and the instruction issued; the Endorsement Guides at 16 CFR Part 255, revised at 88 FR 48102 on 26 July 2023, carry no force of their own.Record
L3Owner releaseHold the post for a named owner; TruHeight, charged 13 April 2026 and closed by final order on 15 July 2026, ran on staff-written reviews and bot social profiles.Gate
L2Moderation guardrailsTest each removal against a documented policy; an agent that quietly suppresses negative sentiment is building the § 465.7 case against its owner.Restrict
L1Confidence thresholdsRoute a thin post to a legal read first; § 465.2 and § 465.8 turn on what you knew or should have known, and the December 2025 warning letters went to advertisers.Require review
Model coreEvidence assembled — the post, its connection, the instruction and completeness
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

  1. E1Final-output evaluationDid the record hold what the post actually carried?
  2. E2Step-level evaluationDid the agent read the right account, the right thread and the live connection?
  3. E3Tool evaluationDid it read and write the correct post record and the correct instruction?
  4. E4Confidence calibrationDo low-confidence posts actually attract more legal corrections?
  5. E5Slice evaluationHow does performance change across specific channel types?
  6. 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 →

  1. 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

  2. 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

  3. 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

  4. 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

  5. 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
See the complete Marketing failure-mode catalogue

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
SliceFailure rateLiftLift vs. thresholdStatus
Employee and insider posts10.5%3.6×Review
Own-site review estate7.5%2.6×Review
Community forum threads4.6%1.6×Watch
Brand account replies2.1%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

  1. 01

    Detect

    Correction rate rises on employee and insider posts.

  2. 02

    Diagnose

    The five-star review written by someone whose payslip the company signs is read back until one cause remains.

  3. 03

    Improve

    Any change goes out numbered, with the posts that caused it attached.

  4. 04

    Verify

    One post case still failing is enough to hold the release back.

  5. 05

    Learn

    One case joins the suite, one line joins the disclosure record.

  6. 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

  1. 01Insider-disclosure discovery and boundary work.Week 1
  2. 02Owned-channel and review-estate sources.Week 1, Week 2
  3. 03Post-to-connection and disclosure-coverage mapping.Week 1, Week 2
  4. 04Post and review ingestion.Week 2
  5. 05Post, connection and record binding.Week 2, Week 3
  6. 06Completeness scoring and review routing.Week 3
  7. 07Owner publication workflow.Week 3, Week 4
  8. 08Community-platform integration.Week 5
  9. 09Connection and instruction cases.Week 4, Week 5
  10. 10Guardrails and moderation controls.Week 4
  11. 11Post-trail instrumentation.Week 5, Week 6
  12. 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 tierPilotOne channel, one yearProductionProduction publication workflowAdvancedMultiple 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 priceFrom $5,000From $8,000Custom 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.

  1. 01Your owned accounts and review estate

    Channel inventory mapping and post capture

    Week 1
  2. 02Representative posts, reviews and community threads

    Record binding, disclosure logic and the coverage baseline

    Week 2
  3. 03Your officers, managers, employees and their relatives

    Channel mapping, connection binding and the automation boundary

    Week 1
  4. 04Access to relevant APIs, feeds or exports

    Channel, review and workforce-source assessment, then integration setup

    Week 2
  5. 05Posts you would not want produced

    Disclosure cases and the failure-mode run

    Week 4
  6. 06What no moderation log may prove

    Completeness scoring, review routing, guardrails and release controls

    Week 3
  7. 07A 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

  1. DiscoveryW1
  2. BuildW2 – W3
  3. EvaluateW4 – W5
  4. 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

AGT-MK-05 · Agent Care available after launch

Build a social agent

Four questions so the call starts from your actual setup — then pick a time that suits you.

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