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As more and more credit unions turn to social media sites such as Facebook, Twitter, Foursquare, and Pinterest (just to name a few) to promote their products and services, most seem to be overlooking the little detail that they are actually engaging in advertising which is heavily regulated.
The same regulations that apply to those post cards you send out or the advertisements placed in your local newspaper also apply to information posted to social media sites. For example, lets say you posted the following to Twitter: “Check out or new 42 month auto loan.” This is an advertisement that includes a Regulation Z trigger term (42 months) which would require you to also disclose the terms of repayment (reflecting the repayment obligations over the full term of the loan, including any balloon payment) and the APR. In this example, not only did you not include the additional required disclosures, but even if you wanted to, do you think you could have squeezed the advertisement and the disclosures into 140 characters (Twitter’s limit)? Probably not.
The same premise applies to Facebook and any other social media site. If you post something it is potentially an advertisement where regulatory requirements from Regulation Z, NCUA Rules and Regulations, and Federal Trade Commission rules could apply.
If you want your head to spin even more, think about this…in the Twitter example above, what if someone responded to your tweet by asking if they qualified for the loan? By replying to your tweet, did they just apply for credit? If they just applied for credit, you have to follow Regulation B and notify them of a credit decision. At the very least, if you don’t respond, you are potentially discouraging them from applying for credit…another Regulation B no no.
So the moral of the story here is to remember that everything you post is a potential advertisement and if you are posting, you need to diligently monitor your sites to make sure nothing is getting posted by others that you are not aware of.
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