Best Practices for Federally Insured Credit Unions’ Advertising, Promotions
March 4, 2014
March 4, 2014
What is an “advertisement” and how does the term apply to the promotional activities of federally insured credit unions?
As we are all aware, all federally insured credit unions must include the National Credit Union Administration (NCUA) information and/or sign in advertisements, which the Code of Federal Regulations defines as “a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business.”
Based on this definition, advertisements would include all print, electronic or broadcast media; displays and signs; stationery and other promotional material; all in-branch printed marketing materials; statement inserts; and website marketing — assuming the piece is designed to attract attention or patronage to a product or business offered by the credit union.
The official NCUA sign should always be visible in material considered to be an advertisement. For instance, the sign should be posted at all tellers’ stations where customer deposits are made. And all advertisements pertaining to deposits should have the official sign or the abbreviated NCUA statement.
It is equally important to keep the following best practices in mind when publishing or posting an advertisement:
- The advertising statement or sign must be legible;
- The font size of the advertisement must not be smaller than the smallest font size used within that particular publication; and
- If only the official sign is used, the credit union can enlarge the sign for better legibility.
The official NCUA advertising statement must be written as follows:
- Long Title: “This credit union is federally insured by the National Credit Union Administration.”
- Short Title: “Federally insured by NCUA”, or
- Official Sign Alone: A reproduction of the official sign can be used as the official advertising statement.
Next, let’s review some of the exceptions to the above. The following are examples of advertisements that do not require the inclusion of the official statement:
- Statements of condition and reports of condition of an insured credit union, which are required to be published by state or federal law or regulation;
- Credit union supplies such as stationery (except when used for circular letters), envelopes, deposit slips, checks, drafts, signature cards, account passbooks, and non-insurable certificates;
- Signs or plates in the credit union office or attached to the building or buildings in which the offices are located;
- Listings in directories;
- Advertisements not setting forth the name of the insured credit union;
- Display advertisements in credit union directories, provided the name of the credit union is listed on any page in the directory with a symbol or other descriptive matter indicating it is insured;
- Joint or group advertisements of credit union services where the names of insured credit unions and non-insured credit unions are listed and form a part of such advertisement;
- Advertisements on radio that do not exceed 30 seconds in length;
- Advertisements on television, other than display advertisements, that do not exceed 30 seconds in length;
- Advertisements that, because of their type or character, would be impractical to include the official advertising statement, such as promotional items like calendars, matchbooks, pens, pencils, and key chains;
- Advertisements that contain a statement to the effect that the credit union is insured by the National Credit Union Administration, or that its accounts and shares or members are insured by the Administration to the maximum insurance amount for each member or shareholder;
- Advertisements that do not relate to member accounts, including but not limited to advertisements relating to loans by the credit union, safekeeping box business or services, traveller’s checks on which the credit union is not primarily liable, and credit life or disability insurance. See 12 CFR §740.5(c) for more details.
Finally, because each situation is fact-specific, you should always consult with your credit union’s compliance officer and/or legal counsel if you have any additional questions regarding advertisement displays.
Created by and for credit unions, CSCU is the industry’s advocate, partner and leader in providing holistic payment solutions that maximize value for both credit unions and their members. For more information about any of CSCU’s products and services, go to www.cscu.net/.
Strategic Link is the NWCUA’s wholly-owned service corporation, using the power of aggregation to provide the Association’s member credit unions with exclusive high-quality, competitively-priced products and discounted services. Contact Director of Strategic Partnerships Craig Reed today to find out how Strategic Link can help your credit union save money while meeting its goals in 2014 and beyond: firstname.lastname@example.org.