PolicyWorks recently conducted a marketing compliance school for CUNA. If you missed out, we will be back in action this September in Anaheim, so I encourage you to join. As usual, there were several questions with respect to the NCUA official advertising sign. Here is one such question.
Is this compliant?
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“To bank or not to bank?” That is the question. William Shakespeare may have written these words in light of the debate brewing in the state of Vermont. It was reported last week that a state regulator had an issue with a credit union over their usage of the words “bank” and “banking.”
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One of the most common compliance issues I see when I am conducting a website audit, or reviewing marketing materials for credit unions, is the use of potentially deceptive or misleading advertising. This is one compliance item that is not always black and white and to ensure compliance, it may take a collaborative effort by compliance officers and marketers alike.
So what do I mean when I say deceptive or misleading? Simple… or is it? Your advertisements should not trick your audience into thinking something, that isn’t really true. Let’s look at an example:
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We recently conducted an advertising workshop for credit unions in conjunction with CUNA. (We will be doing it again in September if you missed it.) We spent some time during the workshop talking about the NCUA official sign and statement. A credit union also recently informed us that during their recent examination the NCUA spent some time reviewing their website and raised the issue of the official sign and statement. So, although we discussed this last month on the blog, here’s some additional information.
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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.
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Here’s something I ran across last week that I thought might be a good reminder:
Do you advertise your dividend-bearing term share accounts as “Certificate of Deposits” on your website? If so, it is time to make a change. It is important to use the correct terminology when advertising these types of accounts.
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As 2011 winds down, it seems we always need reminders of what needs to get done before the end of the year. We have to remember the gifts we need to buy for our loved ones. We need to remember the food that needs to be prepared and brought to the holiday meal. We have to remember to bring the nut roll to Aunt May’s holiday dinner. And we need to prepare our New Year’s resolutions for next year. One reminder that I would like to share, has to do with the compliance date for the updates to the NCUA Regulations for the Share Insurance official advertising statement.
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