5 Smart Compliance Tips for Bank and Credit Union Marketers

When you think of “banking compliance” or “marketing compliance” you might think, that’s not my job! I don’t need to learn about all the regulatory details. Don’t worry, I’m not asking you to do that. I AM saying that these 5 tips can help you save a lot of time and money in the long run AND, in many cases, they may also save time for your compliance team, which may speed up their approval.

1. Involve Your Compliance Team Early in the Process
   • When developing a special campaign offer, involve your bank or credit union’s compliance team at the beginning of the process. By doing that, you’ll know what you can and cannot say or do before you start to write the copy or develop the creative. Nothing is worse than finding out at the last minute that the offer you wanted to use is not in compliance. At that point, you not only have wasted time and money, but you may have to delay the kickoff date.
     
     
2. Read the Copy from the Consumer’s Perspective
   • If you didn’t know anything about the product you are promoting or what certain terms mean, would this ad make sense?
   • Can you interpret the information in more than one way?
   • Does the headline seem to contradict the body copy or the disclosure? For example, does the headline sound like the account is free, but when you read the details, you find there is a $2,500 minimum and direct deposit is required before you can avoid fees? (“What the large type giveth, the small type cannot taketh away.” Federal Trade Commission)

1. As marketers, you need to make sure that you are not deceptive or misleading. Keep these things in mind when you are reviewing the copy and the design. If you see any of the issues mentioned above, take the time to revise the copy now before you send it to your graphic designer and you’ll save time and hassle in the end.
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3. Be Consistent with Terminology
   • If your checking account brochure uses the term “service fee,” your website uses “monthly service charge,” and your “Truth in Savings Disclosure” uses “monthly maintenance fee,” your customer/member may be confused about what this means. Double check that you are using the correct term from the Truth in Savings disclosure consistently to avoid confusion for the consumer. Do this before you send it to your graphic designer and your compliance team.
     
     
4. Use Equal Housing Symbol/Legend
   • When promoting mortgage or home equity products in written and visual ads, check to make sure you have included the Equal Housing symbol (house with equal sign) and the legend verbiage “Equal Housing Lender” or “Equal Housing Opportunity” for state-chartered credit unions. Verify that the verbiage is legible before you send it for compliance approval. (The verbiage should be underneath the Equal Housing symbol and must be legible.)
     
     
5. Use of “Official Sign or Official Advertising Statement” for FDIC or NCUA When Promoting Non-Deposit Investment Products
   • If your ad or website page is only about investment products, conspicuously disclose your approved investment disclosure; do NOT include Member FDIC or NCUA information.
   • If you include both types of products, make sure they are separate and distinct. It must be clear which products are insured by either FDIC or NCUA (use one of the “official” FDIC or NCUA approved advertising statements) and which products are associated with your approved investment disclosure.

These tips can help you save time and money in the long run.

The purpose of this blog is to provide general marketing compliance information to assist you and your compliance department. It is not intended, nor should it be used, as a substitute for consultation with your compliance officer or legal advisor.

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