WASHINGTON (6/27/08)—Many credit unions—and financial institutions in general—feature lobby display boards for selected loan or account rates. But is there a rule that requires that kind of public display? The Credit Union National Association’s June Compliance Challenge
asks readers to consider: Is the rate board required by either Regulation Z or Truth in Savings? The answer is no. Neither Regulation Z nor Truth in Savings requires a federal credit union to maintain a lobby rate board and post loan and share account rates. In fact, neither regulation requires any specific form of advertisement nor do they require a credit union to advertise at all, CUNA’s compliance experts note. According to the Challenge
, once a credit union decides to advertise its products, it must comply with the requirements of Regulation Z if it is advertising a loan product or Truth in Savings if it is advertising a share account product. Credit unions should be aware that both Regulation Z and Truth in Savings define advertisements very broadly. Examples include:
* Messages in a newspaper, magazine, leaflet, promotional flyer, or catalog. Announcements on radio, television, or public address system; * On-line messages, such as on the Internet; * Direct mail literature or other printed material on any exterior or interior sign; * Point-of-sale displays; * Telephone solicitations; * Price tags that contain credit information; * Letters sent to customers as part of an organized solicitation of business; * Messages on checking account statements offering auto loans at a stated annual percentage rate; * Communications promoting a new open-end plan or closed-end transaction.
Use the resource link below to read more on this and other compliance guidance.