A number of releases have come out recently about Hispanic marketing account wins or appointments, and that led me to thinking about a question I honestly don’t have the answer to yet. When brands target their interactive marketing at a Hispanic audience, how well do they do in fulfilling that audience’s online needs?

It’s an issue I first heard raised at a session of the conference on integrated marketing held by the Promotion marketing Association here in Chicago last April. At that panel discussion, titled “Ask an Attorney”, several counsel specializing in promo law mentioned that the Federal Trade Commission is gearing up to get stringent about making sure that brands’ outreach efforts to minority ethnic groups come up to code in everything from product disclosure to opt-in requirements.

“Clients are coming up with a lot of products and services they want to market to a Hispanic audience,” said William Heberer, a partner with Manatt Phelps & Phillips LLP. “But the question is, to what extent are all the ancillary products and services you offer available in Spanish? If you have a Web site or an online membership program that’s purely in English but you market that service to a Hispanic audience, using telemarketing or e-mail in Spanish, then the person who signs up for that is really pretty helpless. It strikes me that the person can’t then get the full use and benefit of the product, because it was sold to them in Spanish but provided in English.”

Paul Stringer, seen right, is executive vice president for Aspen Latino, a division of Aspen Marketing Services. His agency specializes in engagement and retention marketing and thus manages a wide range of tactics from experiential promotions and sponsorships to relationship marketing and direct. Aspen Latino was just named as the activation agency for the Hispanic component of vodka maker Absolut’s “Global Cooling” bar promotion.

Stringer agrees that marketers need to pay more attention to those instances in which marketing to a Hispanic audience means making a whole campaign available in Spanish—including privacy disclosures, game rules, unsubscribe instructions, loyalty program requirements and all those other components that come after the creative concept and the call to action but are just as vital to users.

“As marketers we all want the product experience to live up to the brand promise,” he says. “Your product or promotional campaign could be phenomenal and relevant [to Hispanic customers], but if they can’t fully participate as a result of a language barrier, you’re losing an opportunity to engage that customer fully and may also be failing to build the trust necessary for a long-term relationship.”

If the FTC did choose to compel marketers to be more thorough about making their whole campaigns available in Spanish, Stringer says, it would raise the level of the game for all Hispanic marketing in the U.S.—and make the job of agencies like his that much easier.

“We experience a tremendous level of inconsistency among all the campaign components of our client partners,” he says. “We’ve sometimes found that we’re driving consumers to interact with a product or promotion, only to find that it’s not happening because the client partner is not up to speed from a communications perspective.”

Stringer says his agency is currently working with a financial services client to make sure that their back-end communications—all the agreements, rules and regulations—are available in Spanish before the front-end promotion rolls out.

“We typically operate at the end of the promotional communications process, crafting promotions that engage the consumer,” he says. “But making sure that language is target-right and relevant is less of an undertaking than making sure that every one of the touchpoints at the internal company—from the customer-service representatives to invoices and applications—is available to Hispanic customers.”

About 85% of Hispanic consumers over 18 are either bilingual or Spanish-dominant, and about 40% of that group doesn’t speak English well, Stringer says. Since most Hispanic households are both multilingual and multi-generational, parents often rely on a child to translate marketing content for them.

“That’s how a lot of brands are making progress into Hispanic households, but it’s really an additional step that doesn’t need to be there,” Stringer says. “These consumers are already active in the marketplace.” Well-crafted promotions should drive the emotional connection to a brand as well as the conversion action—but if you’re relying on some third party such as a son or daughter to convey your campaign’s value message to your target consumer, you’re throwing away that chance to build affinity, he says.

“Having complete in-language communication works toward maximizing involvement,” he says. “And from an emotional perspective, showing that your brand has gone that extra mile to make sure that a program is universally available, you can build tremendous trust with these consumers.”

This multilingual approach is just as important in online or interactive promotions—maybe more so, because Hispanics are now among the fastest-growing digital constituencies in the U.S.

However Stringer points out that the Hispanic market is not monolithic, and that campaigns aimed at a young, affluent demographic—like the Absolut “Global Cooling” initiative—may find their target market segments are equally comfortable in English and Spanish. Taking aim at those segments may be less about fulfilling their language needs and more about supplying the cultural cues that help them engage with a campaign.

What do you think? Do brands do a good enough job of following through, both online and off-, on their campaigns to win over Hispanic consumers? If broad markets remain tight, it’s a question that may loom larger in the coming year—both for brand marketers and for the federal and state regulators who watch them.