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Five Compliance To-Dos for Credit Union Marketers

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BY BRIAN GODWIN

The stream of regulations credit unions must adhere to these days seems virtually endless. And staying compliant with all these rules can get in the way of CU marketers’ execution of prosperous campaigns. These five easy strategies will ensure both compliance and success.

Accompanying every regulation, financial product and marketing channel isa new set of rules. With so many minute consumer-protection requirements across financial product lines, it’s important for credit union marketers to ensure they do not miss important details as they go through the day-to-day effort of promoting their cooperatives. What follows are five simple tips for helping credit union marketers plan and execute successful, compliant marketing campaigns.

Get all hands on deck.

Today’s complex regulatory world calls for an all-hands-on-deck approach. When designing and approving marketing materials, work as a team, albeit with clear separation. Be sure the individual or group creating the material is independent of the individual or group reviewing it. If possible, the same individual or group should review each and every item that leaves the credit union. (This includes social media posts.)

Train, train and train again.

To ensure marketers are set up for valuable contribution to the credit union’s compliance program, invest in relevant regulatory training for them. Ensure new marketers are trained immediately or shortly after their start dates. Create checklists to help them achieve compliance easily, painlessly and in a way that doesn’t strangle creativity. Educate those marketers who are managing Twitter, Facebook, Snapchat and other social accounts on the use of trigger terms as well as the additional disclosures they could require.Many of these social platforms do not allow sufficient characters to include all necessary disclosures should they be triggered.

It’s also a good idea to provide a high-level overview to all staff as it relates to personal posts on their social media outlets.A well-intentioned employee may post about a specific interest rate on his or her personal platform, without stating the rate as an APR or without including other applicable disclosures.Even personal posts may carry some compliance risk if it is apparent the individual is associated with the credit union.

Remember the website.

In the world of digital marketing, content is forever in flux. New content, in the form of fresh posts or updated copy, is added often and typically very quickly – because that’s what an online audience demands. This speed to deliver can make compliance reviews tricky. In cases where your credit union needs a quick turnaround, consider working with a partner that specializes in turn-on-a-dime reviews. Websites, social accounts and mobile marketing are extremely visible to members and regulators, too. Make sure your online communication is on point, checked often and follows a good compliance review procedure before clicking “Publish.”

Be very mindful of UDAAP.

Put yourself in the shoes of the average member or prospective member when developing new products and reviewing marketing materials. Viewing your products, communications, advertisements and public statements from the consumer’s perspective can help you avoid the use of industry acronyms that can be confusing or off-putting. Be careful not to use affirmative statements such as “Get a loan!” That kind of language could be considered misleading because not all who apply may be approved.

Consider fair lending.

As you are reviewing from inside the consumer’s shoes, ask yourself: Is this advertisement, direct mail or web banner welcoming to all? Is it inclusive of each demographic that makes up our entire community? Be cognizant of the people used to illustrate your print ads, billboard creative and social network account pages. It should be a goal to represent each of the member groups in your field of membership.

In addition, be aware of the contacts in your target audience database and the channels you are using to reach them. Care must be taken when using addresses, for example, to craft a direct mail campaign. Emerging methods such as geofencing, which targets consumers in a specific geographic area, can also present fair lending challenges. Some cities and towns have distinct minority variations throughout the community. By marketing to certain neighborhoods, the credit union may inadvertently exclude a protected class, creating a fair lending concern.

Marketers love to flex their creative muscles. It’s in their nature to push the boundaries. Getting your marketing house in order will ensure they can do exactly that, with the added assurance they won’t fall over the edge.

Brian Godwin is director of compliance solutions for regulatory compliance firm PolicyWorks, a national leader of credit union compliance solutions. He can be reached at briang@policyworksllc.com.

 

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