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Compliance Advertising rates during volatile time
WASHINGTON (2/21/08)—In a volatile rate environment, can a credit union marketing department make it’s best informed guess at where its board will set next week’s rates and advertise based on that prediction? The Credit Union National Association’s (CUNA’s) February Compliance Challenge quizzes, What’s a marketing department to do when a deadline for a newspaper ad runs ahead of a rumored rate change? The Challenge poses this situation: A credit union marketing department wants to place an ad in the local newspapers for Home Equity Lines of Credit (HELOC) the following week. Rumors running throughout the credit union indicate the board of directors may approve a reduction in the HELOC APR to 5.25% at its meeting early next week. The trouble is the ad deadline is now. May the marketing department assume that the board will reduce the APR for HELOCs to 5.25% and advertise that in the newspapers? No. No. No. The marketing department should not advertise a HELOC APR of 5.25% based upon an assumption because the board may not actually agree to reduce the rate at all or may not reduce the APR as low as 5.25%, CUNA compliance experts warn. Regulation Z (Section 226.16(a)), implementing Truth in Lending Act provisions, requires a credit union only to advertise credit terms that will actually be made available to members. For more on this and other credit union compliance issues, use the resource link below to take the Compliance Challenge.


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