. • The official advertising statement must in substance state: "Member of the Federal Deposit Insurance Corporation." • Alternatively, the short title "Member FDIC" or a reproduction of the FDIC symbol may be used. The unique thing about NCUA's advertising rule is that it actually requires a disclosure to appear in all advertisements – the official advertising statement. NCUA's official advertising statement: The exceptions. Part 2 of 2Today we are releasing Version 2 of the CFPB Supervision and Examination Manual, the guide our examiners use in overseeing companies that provide consumer financial products and services. Official Advertising Statement 3 Options for Disclosure 1. If your bank or credit union uses social media, then you have to comply with the disclosure laws by including the official advertising sign like member FDIC or federally insured by the NCUA. SUITE 400 253 0 obj
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"Specifically, in 2011, while banks needed only to include the FDIC advertising statement in radio and television ads that exceeded 30 seconds, the 2011 NCUA rule change required FICUs to include NCUA's official advertising statement in radio and television ads that exceeded 15 seconds. In addition to the rules in the applicable regulation, NCUA also has some general advertising rules. BOISE, ID 83705, 13221 SW 68TH PKWY, . The basic point of these rules is that your ad must be accurate. As first glance, this seems a bit counterintuitive to NCUA's advertising rules. (Source: NCUA) In a 2-1 vote by the NCUA board, the agency approved a final rule to allow CUSOs to originate any type of loan originated by a federal credit union. 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. Each credit union member must display only the official MSIC member sign at each place where a member transaction may take 1. (iii) Insured by NCUA; or (iv) A reproduction of the official sign as described in § 740.4(b) may be used in lieu of the other statements included in this section. And all advertisements pertaining to deposits should have the official sign or the abbreviated NCUA statement. This statement must be used when placing an add in a publication or statement and even that requirement has specific requirements. (a) Advertisement defined. Official status. Posted in Marketing & Communications, NCUA. See, the advertising statement is all about how your credit union is insured but only your accounts are insured. Specifically, insured credit unions will be required to include the statement in.all radio and television advertisements, annual reports, and statements of condition required to be published by law. 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. What is an “advertisement” and how does the term apply to the promotional activities of federally insured credit unions? The three versions of the official advertising statement are as follows: "This credit union is federally insured by the National Credit Union Administration." "Federally insured by NCUA . Found inside – Page 18... MERGERS AND ACQUISITIONS course of their official duties ( DC DC ) 644 See also BANK HOLDING COMPANIES ; -NCUA official ... since he continued objections 540 to receive improper periodic statements — Illinois , South Chicago Savings ... To download a copy using Internet Explorer, right click on the link. endstream
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<. This commentary is the means by which the staff of the Office of General Counsel of the National Credit Union Administration issues official staff interpretations of Part 707 of the NCUA Rules and Regulations. The NCUA has published [82 FR 46173] a proposed rule that would amend its rules at 12 CFR part 740 (Accuracy of Advertising and Notice of Insured Status) to add a fourth version of its official advertising statement -- Insured by NCUA -- to those allowed for use by federally-insured credit unions, to expand a current exemption from the advertising statement requirement for topic pages. Radio and television advertisements that are less than 15 seconds. This latest amendment changes when the "official advertisement statement" is required. 2. 7.1.3 Evidence of Over-reliance on Credit Rating Legislative References -- 7.2 Anticipating the Post-crisis Debate on Over-reliance -- 7.2.1 CRA Message to the Regulators -- 7.2.2 CRA Message to the Users of Credit Ratings -- Concluding ... 4311. But there is one unique thing about NCUA's advertising rules. In its use of a trade name, a State Credit Union must exercise due diligence to assure that it is in List any trade names the credit union uses for signage or advertising. Under this NPR, the title of 12 CFR Part 328, currently "Advertisement of Membership" would be changed to "Advertisement of Membership . Latest developments from the NCUA (National Credit Union Administration), prudential regulator of federal credit unions and savings insurer for members of federal and state credit unions. "Federally insured by NCUA." Use of the official NCUA share insurance logo. (iv) A reproduction of the official sign as described in § 740.4(b) may be used in lieu of the other statements included in this section. Found inside – Page 947No teller in a nonfederally insured credit union may display the official NCUA sign. ... (a) Each insured credit union must include the official advertising statement, prescribed in paragraph (b) of this section, ... and may be no smaller than the smallest font size used in . Section 740.5(a) states that "each insured credit union must include the official advertising statement . Found inside – Page 23If daily dividends are offered , the yield will not be less than stated ; and the disclosure statement unnecessary . --When advertising dividends , FCUS must state ( effective March 1 ) that dividends are based on the CU's earnings at ... The term "advertisement," as used in this part, shall mean a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business. 3 Options for Disclosure. If the official sign is used as the official advertising statement, an insured credit union may alter the font size to ensure its legibility as provided in § 740.4(b)(2). NCUA has defined "advertisement" as: a commercial message, in any medium, that is designed to attract public attention or patronage to a product or business. Is the ncua advertising statementor its short version accompanied by the ncua logoon every page that advertises deposit account products. Found insideCREDIT Each member account insured to $ 20,000 NATIONAL NOINT ADMINI NCUA by Administrator , National Credit Union ... The regard to the official advertising stateofficial advertising statement shall be in ment and manner of use ... (b) Official advertising statement. Commenters were fairly evenly split on their preferences. Buying, selling, budgeting, and saving are fundamental business practices that almost everyone understands on a basic level. in all of its advertisements." . %PDF-1.5
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SUMMARY: Section 740.4 of NCUA's rules requires that a federally insured credit union continuously display the official NCUA sign at every teller station or (iii) Insured by NCUA; or (iv) A reproduction of the official sign as described in § 740.4(b) may be used in lieu of the other statements included in this section. If any of you have ever asked us an advertising question, you probably got some version of this somewhere in the response: "'Advertisement' is defined very broadly in [insert applicable regulation here] to cover any commercial message that promotes your [insert product or service here]." Providing credit unions with the best federal advocacy, education and compliance assistance in the industry, © 2021 National Association of Federally-Insured Credit Unions, NCUA's Official Advertising Statement: The Exceptions, CECL Study: Alternatives, Impacts, Accuracy, and Complexity, NCUA CUSO Rule Changes Poised to Go into Effect, http://www.youtube.com/user/NAFCUtv?feature=g-all-u. Federal Credit Unions (NCUA): 12 CFR 701.31(d) Federal Savings Associations (OCC): 12 CFR 128.4; Non-Member State Banks (FDIC): 12 CFR 338.3; State Savings Associations (FDIC): 12 CFR 390.145; State Member Banks (FRB): Federal Reserve Board Order on Fair Housing Advertising and Poster Requirements of March 20, 1989 (54 Fed. The rules instead work around "trigger terms" – if a credit union states a particular terms in the advertisement, certain additional disclosures are required.
The questions can range from whether a particular message is considered an advertisement to the specific content requirements for advertisements. NCUA had proposed to remove three exemptions to its requirement to disclose the "official . It requires that all other kinds of advertisements be accurate. Statements and Testimony; CEA Studies and Reports; NFA Documents; . A financial statement/annual report is available upon request for any current or potential member. Credit union accounts are insured up to $250,000 by the . Save the file to the directory and folder of your choice. The administrative agencies responsible for enforcing the regulation may require . So, the basic point is that if your credit union puts out any message about a product or service, it's probably going to be an advertisement. Found inside – Page 538( 1 ) NCUA will automatically supply all insured credit unions an initial supply of official signs with a blue background ... ( 1 ) An insured credit union must include the official advertising statement in its advertisements thirty ( 30 ) ... All Rights Reserved. The National Credit Union Administration (NCUA) has proposed changes to advertising requirements that could force some credit unions to reduce or eliminate some of their current marketing practices. The short title. Thirteen commenters favored use of NCUA while eleven preferred use of NCUSIF. Found inside – Page 737The bill also would replace the price limit for homes these NCUA Publishes Final Rule Governing Advertising , Statement on Deposit Insurance mortgages can finance with a simple limit . T he National Credit Union Administration May 2 ... Agencies. Section 740.5(c) provides a rather long list of advertisements that do not have to include the official advertising statement. After a cursory review of our hosted websites, we do not believe any changes will be required to your websites. Found inside – Page 547Furthermore , cach subsidiary page of an on - line system that contains an advertisement should display the official advertising statement unless subject to one of the exceptions described under $ 328.3 ( c ) ( NCUA RR 3740,4 ( c ) ) . Use of ncqa logo. NCUA's advertising rule requires federally insured credit unions to use NCUA's "official advertisement statement" when advertising. Found inside – Page 779( 1 ) An insured credit union must include the official advertising statement in its advertisements thirty ( 30 ) ... by NCUA ” or a reproduction of the official sign , as described in $ 740.4 ( b ) , as the the official advertising ... The official NCUA advertising statement is also required to be clearly visible on the page in a size and print that is no smaller than the smallest font size used on the related webpage. 1. She also contributes toward the organization’s various communications plans, unifying credit union voices to strengthen the Movement. (a) General rule. Credit union supplies such as envelopes, deposit slips or signature cards; Advertisements that do not state the name of the insured credit union; Group advertisements of credit union services where names of insured and noninsured credit unions are listed; and. In addition, in order to comply with both Massachusetts law and NCUA regulations, MSIC Advertising Guidelines strongly recommend that our members: Display the MSIC sign (logo) additionally at each location required by the NCUA for the NCUA official sign. INDEX 2010-2021 BCG 2 AMERICANS WITH DISABILITIES ACT Ninth Circuit Validates ADA Website Claims Nov 2019 If you remember our compliance forecast from January 11 th we discussed the NCUA's intentions to amend the NCUA official advertising statement rule. As a social media lawyer that specializes in social media compliance for banks or social media compliance for credit unions, I'm here to tell you how you . Part 740.5(b) of NCUA's Rules and Regulations authorize three versions of an official advertising statement. Found inside – Page 338Any credit union that does not have an adequate supply but requests additional signs from NCUA shall not be deemed to have violated ... §740.4 Mandatory requirements with regard to the official advertising statement and manner of use. %%EOF
are in compliance with this Interpretive Statement, need not fmiher notify the Director of Credit Unions incident to the issuance of this Interpretive Statement. 7 NOTE: The official advertising statement must be in a size and print that is clearly legible and may be no smaller than the smallest font size Since these examples are not exhaustive, a number of other products and services can be covered under this exception. Th e offi cial sign. Written by Steve Van Beek. official advertising statement insured credit unions must include in their advertisements. The . SUITE 1102 Found insideExempt all indoor lobby signs from certain advertising requirements . Repeal TISA's civil liability provisions effective September 30 , 2001 . mittee audit responsibility• A “ balance sheet audit ” ; • A “ review and evaluation of ... Presents a series of "short-term" and "intermediate-term" recommendations that could immediately improve and reform the U.S. regulatory structure. NCUA Staff Commentary On November 8, 1994, NCUA issued its Official Staff Interpretation (Commentary) to the Truth In Savings Rule (Part 707) incorporating much of the Supplementary information issued with Part 707 and addressing additional compliance questions. "Federally insured by NUA" 3. If the official sign is used as the official advertising statement, an insured credit union may alter the font size to ensure its legibility as provided in § 740.4(b)(2). If the official sign is used as the official advertising statement, an insured credit union may alter the font size to ensure its legibility as provided in § 740.4(b)(2). 276 0 obj
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In the long version the official advertising statement reads. 11567-11568 . If the official sign is used as the official advertising statement, an insured credit union may alter the font size to ensure its legibility as provided in § 740.4(b)(2). "This credit union is federally insured by the National Credit Union Administration." 2. . 1. In this role, she oversees NWCUA’s weekly newsletter, Anthem, and contributes to it weekly as a lead writer. Display MSIC's counter tents at each teller station and member service representative's desk. 294 0 obj
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By January 1 st, 2012, you must be in compliance with the updates to Part 740.5 of the NCUA Regulations that state that credit unions will need to ensure that the official advertising statement is included with all radio and TV ads longer than 15 seconds and must me included on all annual reports and statements of condition. (c) Use of official advertising statement in advertisements—(1) General requirement. In our compliance inbox, we often get asked about advertising requirements. The proposed rule on advertising would provide regulatory relief to federally insured credit unions by allowing a shorter version of the official advertising statement "Insured by NCUA." The proposal would expand the radio and television exemptions to advertisements that are less than 30 seconds (currently 15 seconds) in duration. Section 740.5(a) states that "each insured credit union must include the official advertising statement . The other regulations that govern advertisements, such as Truth in Savings and Regulation Z, do not require credit unions to always have a particular disclosure in an advertisement. 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. In addition, it is eliminating the requirement to include the official advertising statement on statements of condition required to be published by law. The following logos were created at 300 dpi. Ncuas rules and regulations part 740 can be summarized as follows. Good faith compliance with this commentary affords protection from liability under section 271(f) of the Truth in Savings Act (TISA), 12 U.S.C. While, of course, credit unions may include the official advertising statement on advertisements that do not relate to member accounts (except for noninsured investment products), it is one thing you can take off your checklist for these types of advertisements. A creditor shall retain evidence of compliance with this part (other than advertising requirements under §§ 1026.16 and 1026.24, and other than the requirements under § 1026.19(e) and (f)) for two years after the date disclosures are required to be made or action is required to be taken. The regulation contains information on the types of advertisements which do not require the official advertising statement. Advertising Guidelines Approved; September 29, 2010 To All MSIC Member Credit Unions: Massachusetts law and your policy of insurance with MSIC require that your institution only use official MSIC signs and statements. Part 740.5(b) of NCUA's Rules and Regulations authorize three versions of an official advertising statement. NCUA official seal. A federal credit union can adopt a trade name for use in advertising but its official charter name, which must have the word "federal credit union" in it, must be used in all official or legal communications or documents. DDA: Deposit Insurance or Share Insurance: Whenever a depository institution advertises FDIC-insured products, regardless of delivery channel, the institution must include the official advertising statement of FDIC membership, usually worded, "Member FDIC." Each insured credit union must include the official advertising statement of NCUA . official NCUA sign and insurance statement. If only the official sign is used, the credit union can enlarge the sign for better legibility. Credit unions can also use a reproduction of the official sign as the advertising statement. Here are some of these exceptions: These can all come in handy from time to time, but, the most important exception, in my humble opinion, appears last on the list: advertisements that do not relate to member accounts. Found inside – Page 1228One implication of this allegation tion will result in three distinct sources of is that if the NCUA rule regarding the economic injury . First , it alleges that the official sign and advertising statement is appearance of the phrase ... Found inside – Page 40( 3 ) A copy of a standard disclosure statement for each class or type of account offered by a Federal credit union shall be ... ( j ) Advertising - In addition to the advertising requirements established in Part 740 of the Rules and ... NCUA's regulations prohibit federally-insured credit unions from using any advertising, displays, signs, stationery, or other promotional material that is "inaccurate or deceptive in any particular." 12 C.F.R. Those regulations list "triggering terms . Nondeposit Investment Products. ( 2 ) The official advertising statement must be in a size and print that is clearly legible and may be no smaller than the smallest font size used in other portions of the . In the long version, the official advertising statement reads: "This credit union is federally insured by the National Credit Union Administration." The rule provides a couple of examples of the types of advertisements this exception covers: advertisements for loans, safety deposit boxes, traveler's checks and credit disability insurance. This affects how the NCUA blue box or disclaimer copy is presented on your website. Part 740 - Accuracy of Advertising and Notice of Insured Status. �`
The NCUA finalized the requirements for the official advertising statement in the monthly board meeting early this week. revise certain provisions of NCUA's official advertising statement rule. You can also pull up our financial data by clicking on NCUA on our Service Partner icon and use charter #11927 as our identification. in the official sign and advertising statement concerning insurance coverage. The second was a rule published under the Federal Trade Commission (FTC) Act and was issued jointly with the Office of Thrift Supervision (OTS) and the National Credit Union Administration (NCUA). If the official sign is used as the official advertising statement, an insured credit union may alter the font size to ensure its legibility. Currently, there are two versions of the NCUA's official advertising statement: (1) The longer version, which reads "This credit union is federally insured by the National Credit Union Administration"; and (2) the shorter version, which reads "Federally insured by NCUA." In accordance with part 740, a FICU may, as a third option . Check out our resources for journalists, bloggers, communicators, and marketers. Except as provided in § 328.3(d), each insured depository institution shall include the official advertising statement prescribed in § 328.3(b) in all advertisements that either promote deposit products and services or promote non-specific banking products . NCUA Expands Advertising Requirements for NCUA Official Statement Jun 2011 Proposal Would Expand Requirements for NCUA Official Statement in Ads Apr 2011 . The proposal also defines the term SUITE 100 The unique thing about NCUA's advertising rule is that it actually requires a disclosure to appear in all advertisements - the official advertising statement. Congress designed the NCUA to protect credit unions and its members. So, I'll just say that even when a message is considered an "advertisement," you may not actually need to include the official advertising statement thanks to some exceptions. Found inside – Page 833No teller in a nonfederally insured credit union may display the official NCUA sign . ... ( a ) Each insured credit union must include the official advertising statement , prescribed in paragraph ( b ) of this section , in all of its ... General deposit information fdic insured bank advertisements must include the fdic official advertising statement when ad includes any deposit products/services or promote. . The NCUA fills a similar role with credit unions that the FDIC does with banks. • National Credit Union Administration • §701.31 - Fair Housing Rules and Equal Credit Opportunity • §740 - NCUA Official Advertising Sign/Statement • §707- Truth in Savings • FTC. The NCUA will use this information for official correspondence with the Supervisory Committee (such as forwarding member complaints). Here is what you need to know: 1. Â One of the final rules will impact every credit union. A Save As window will appear. NCUA revised the requirements for use of the official insurance sign and official advertising statement to permit federally insured credit unions flexibility in advertising. Â NCUA finalized an amendment to change its requirements for the "official advertising statement."Â In 2008, NCUA amended the "official advertising statement" to allow credit unions three options. Additionally, the NCUA Board is expanding a current exemption from the advertising statement requirement regarding radio and television advertisements. Th e NCUA offi cial advertising statement may be displayed as one of three options: 1. For more information about any of CSCU’s products and services, go to www.cscu.net/. But financial institutions have to ensure their ads follow the applicable regulations, such as Regulation B, Regulation Z, Regulation DD, Fair Housing Act. This commentary is the means by which the staff of the Office of General Counsel of the National Credit Union Administration issues official staff interpretations of Part 707 of the NCUA Rules and Regulations. Good-faith compliance with NCUA's commentary affords credit unions pro - 5 NCUA • Primary areas of Supervisory and Examination focus by NCUA in 2017/2018 Reg. The use and reproduction of ncqas logo is strictly prohibited. Federal Credit Union: NCUA regulates and insures federal credit unions. If the credit union is an agent of a third party credit . TIGARD, OR 97223, 18000 INTERNATIONAL BLVD, solicitations, new accounts, periodic statements, change in terms notifications, and advertisements. Any Exceptions? If the official sign is used as the official advertising statement, an insured credit union may alter the font size to ensure its legibility as provided in § 740.4(b)(2).
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