DES MOINES, Iowa (1/13/12)--A new white paper from PolicyWorks provides credit unions with tips for ensuring their online marketing and advertising efforts meet compliance and disclosure standards.
"Credit unions are held to many of the same regulations governing the big banks and the way they advertise their products and services," wrote author Kyle Woodmansee, PolicyWorks compliance officer. "Therefore, they need to apply as much scrutiny and due diligence to their creative messages as do large financial institutions."
The white paper addresses four questions related to communicating online:
- Is the newsletter really 'for members only?' Once they are published, online newsletters that previously were mailed only to members are open to public viewing. Once a newsletter becomes available to the public, new regulations apply.
- How free is "free?" Free checking is a key differentiator for credit unions in the wake of the new interchange rule and Bank Transfer Day. It's important for a credit union's marketing team to fully understand the fee structure behind "free checking" before advertising it as such.
- Is the giveaway being promoted more than $10? Giveaways are popular marketing promotions. Credit unions, though, are governed by specific rules about communicating a giveaway that is considered by the National Credit Union Administration to be a "bonus"--a premium, gift, award or other consideration work more than $10 given to a member for opening, maintaining or renewing an account or increasing an account balance. There is a large list of disclosures that must accompany the promotion. Those disclosures require screen space and bandwidth.
- Does the message pull the disclosure trigger? There's a long list of promotional terms that will trigger warning terms for an examiner. "No closing costs," "0% annual percentage rate," and "No balance transfer fee" are among them. Most of these require additional disclosures. Providing those disclosures online--in a YouTube video, for example--can be a challenge.