NCUA Advertising Regulations - Business Law Firm .

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NCUA AdvertisingRegulationsApril 19, 2017E. Andrew Keeney, Esq.Kaufman & Canoles, P.C.15389866v3

E. Andrew Keeney, Esq.Kaufman & Canoles, P.C.150 West Main Street, Suite 2100Norfolk, VA 23510(757) /movies/credit-unions.html2

Overview and Agenda Advertising Rules and Regulations CFPB, NCUA, FTC, FCC Advertising Avenues Website, Email, TV, Radio, Print Products Examples Loans, Savings, Safe Deposit Boxes, Night Drop,Promotions & Drawings Checklist Best Practices/Key Takeaways3

Regulations CFPB UDAAP Regulation Z Truth in Lending National Credit Union Administration §701.31 – Fair Housing Rules and Equal CreditOpportunity §740 – NCUA Official Advertising Sign/Statement §707– Truth in Savings FTC4

NCUA Primary areas of Supervisory and Examinationfocus by NCUA in 2017/2018 Cybersecurity RiskBank Secrecy Act ComplianceInternal Controls and Fraud PreventionInterest Rate and Liquidity RiskCommercial LendingConsumer Compliance Military Lending Act SCRA5

CFPB UDAAP6

Regulation Z –Truth in Lending An "advertisement" under Truth in Lending Regulation Z is any commercial message thatpromotes consumer credit "Advertisements" may appear: In newspapers, magazines, leaflets, flyers, catalogs,direct mail literature, or other printed material On radio, television, or a public address system On an inside or outside sign or display, or a windowdisplay In point-of-sale literature, price tags, signs, and billboards7

Regulation Z –Truth in Lending Clear and Conspicuous Requirement No font size requirement Legible and easily understood Actual Availability of Terms Never advertise credit terms not available If conditions exist, state in the advertisement8

Regulation Z –Truth in Lending Annual Percentage Rate (APR) Yes, use of either is acceptable Trigger Terms Additional disclosures are mentioned in ad “Unsecured” and “Signature” Avoid use of these terms Alternative Disclosure Rule for TV/Radio Ads State APR and include toll free number Special Disclosure Rule for Website Ads Fall under same rules as catalogs and multi-pages ad9

NCUA§701.31 & Equal Credit Opportunity When advertising loans for the purpose ofpurchasing, constructing, improving,repairing, or maintaining a dwelling, theadvertisement must prominently indicate ina manner appropriate to the advertisingmedium and format that the Credit Unionmakes such loans without regard to race,religion, or other discriminatory factors10

NCUA§701.31 & Equal Credit Opportunity The Credit Union must: Include the Equal Housing logo and slogan in all writtenand visual advertisementsInclude a statement in oral advertisements that theCredit Union is an “Equal Housing Lender”Use either of the two methods described above when anoral advertisement is used in conjunction with a writtenoneNot include in any advertisement words, symbols,models, or other forms of communication that express,imply, or suggest a discriminatory preference or policyof exclusion11

NCUA Fair Lending Prohibition against credit discrimination based on: RaceColorReligionNational OriginSexMarital StatusAgeIncomeDerived from Public AssistanceExercise of Rights Under Consumer Credit Protection Act12

NCUA Fair Lending No advertisement that indicates discrimination on anyprohibited basis No advertisement that suggests a preference orexclusion on a prohibited basis Written/visual advertisement requires Equal HousingLender/Equal Housing Opportunity logotype Oral advertisement requires Equal HousingLender/Equal Housing Opportunity statement Lobby notice clearly visible to public required in eachlocation where loans are made13

NCUA Fair Lending Fair Lending – Other Laws Servicemember’s Civil Relief ActUnfair Deceptive Acts or PracticesFair Debt Collection Practices ActFair Credit Reporting Act14

Equal Housing Sloganand Logo15

Fair Housing Poster Must display the Fair Housing Poster Public Lobby Areas/Offices where loans are made Websites that accept loan applicationsonline may be considered a “lobby” forFair Housing compliance purposes16

FTC “4 P’S” Is the statement Prominent enough for a consumer tonotice? Is the information Presented in an easy to understandformat that does not contradict other information in thepackage or at a time when the consumer’s attention isnot elsewhere? Is the Placement of the information and the locationwhere the consumer can be expected to look or hear? Is the information in close Proximity to the claim itqualifies?17

NCUAShare Insurance Advertising Share Insurance Brochure /NCUAHowYourAcctInsured.pdf Lobby1818

NCUA§740 – Advertising Sign/Statement A federally insured Credit Union mustdisplay the NCUA advertising sign: At all teller stations and offices that acceptdepositsOn the homepage of websitesOn all advertisements for share accountsOn the first page of posted financialstatementsOn the first page of Annual Reports19

NCUA§740 – Advertising Sign/Statement20

NCUA§740 – Advertising Sign/Statement Three Options ”This Credit Union isfederally insured by the National CreditUnion Administration.” Short Title. “Federally Insured by NCUA.” Use of the Official NCUA Share InsuranceLogo. The Question – When?21

NCUA§740 – Advertising Sign/Statement Advertisement as defined by NCUA Advertisement according to NCUA means acommercial message, in any medium, that isdesigned to attract public attention orpatronage to a product or business.22

NCUA§740 – Advertising Sign/Statement Font Size For advertising purposes, the text in the NCUAlogo or the “federally insured by NCUA text”must be in a size and print that is clearly legibleand may be no smaller than the smallest fontsize used in other portions of the advertisement23

NCUA§740 – Advertising Sign/Statement Downloadable Data, Images, and Softwarefor Signage Check NCUA website24

NCUA§740 – Advertising Sign/Statement The official sign must be posted at eachteller station. Any exceptions? Credit Union supplies such as stationery,envelopes, deposit slips, checks, drafts,signature cards, passbooks. Plates in the Credit Union office are attached tothe building where the offices are located Listings and Directories25

SHARE INSURANCE SIGNS ANDDOWNLOADABLE GRAPHICS – BY NCUA NCUA has some downloadable ShareInsurance Graphics/EnCUSBsign.pdf NCUA has an online order form for ShareInsurance Funds e-ncua-publications-order-form.pdf2626

NCUA§740 – Advertising Sign/StatementExceptions (continued) Advertisements that do not include the name of theCredit Union Video advertisements that do not exceed 15 seconds inlength Television advertisements other than displayadvertisements that do not exceed 15 seconds in length Advertisements of the type or character making itimpractical to include the official advertising statementincluding such items as calendars, matchbooks, pens,pencils, key chains, and golf balls27

NCUA§740 – Advertising Sign/Statement Advertisements when the internet/webpageof the Credit Union is an ad28

Checklist WHAT IS IN YOUR LOBBY?Customer/Member Identification Program NoticeNCUA Official SignNCUA Official Advertising StatementLender/Equal Housing Opportunity Provider PosterNondiscrimination in AdvertisingHome Mortgage Disclosure Act NoticeFunds Availability NoticeFinancial StatementAmericans With Disability Act“APR” and “APY” Requirements under Truth in Lending andTruth in Savings29

Batesville-WRBI-FIN30

Quicken Loans31

Radio Disclaimer32

PenFed33

CITY LOAN 180 TURNAROUND LOAN34

Vomitus Legalis35

36

37

38

SurveyHave you used a vendor to do yourmarketing designs or promotions? Yes No39

SurveyAfter this program, will you or the MarketingDepartment be using the checklist provided to verifythat your Credit Union is in compliance with theNCUA advertising regulations? Yes No40

SurveyDoes your Credit Union advertise on TV? Yes No41

SurveyDoes your Credit Union advertise on the Internet? Yes No42

Key Takeaways NCUA advertising requirements can impact safetyand soundness Marketing Compliance Management Check and double check advertising avenues –website, email, TV, radio, and print Follow FTC 4 P’S! -- Prominent; Presented;Placement; Proximity Don’t follow the crowd!43

E. Andrew Keeney, Esq.Kaufman & Canoles, P.C.150 West Main Street, Suite 2100Norfolk, VA 23510(757) /movies/credit-unions.html44

NCUA AdvertisingRegulationsApril 19, 2017E. Andrew Keeney, Esq.Kaufman & Canoles, P.C.

§740 – Advertising Sign/Statement Advertisement as defined by NCUA Advertisement according to NCUA means a commercial message, in any medium, that is designed to attract public attentio

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