Social Media Compliance Risk

​Four tips to help your credit union minimize risk while still creating and maintaining a social media presence your marketing team can use! 

Social media is a great way for credit unions to reach current members and promote products and services to potential members, but it is a common area of compliance confusion — something that can create tension between a credit union’s compliance and marketing teams.

Advertising regulations apply the same way to social media posts as they do to other advertising formats and websites. There are no free passes for social media, which can be frustrating to marketing teams trying to present a more fun persona or keep messaging short, but there just aren’t any exceptions.

Below are a few tips that can help credit unions minimize their social media compliance risk.

1. Present Key Items Legibly
Specifically, the National Credit Union Administration (NCUA) official advertising statement and Equal Housing Opportunity logo need to be present when applicable and must be legible. A simple way to ensure you are staying compliant is to add these items clearly and legibly on your credit union’s main cover image, like the large banner images you see on Facebook or LinkedIn. Then you don’t have to worry about including these items in each post. By using the NCUA statement in your cover image rather than the sign, you avoid the legibility issues often associated with the text within the sign.

2. One-Click Disclosures
If a trigger term for certain products (such as an APY) is part of your social media post or ad, the required trigger term disclosures should be made available within one click. Make sure this is clear to viewers by stating something like “click here to view disclosures.”

A better approach might be to avoid trigger terms in the posts and ads in the first place. Not only does doing so save space, but it also eliminates possible roadblocks for both the marketing and compliance teams.

3. Say What You Mean
In an attempt to catch viewers’ attention, you could end up being unclear in your message. For example, stating “Get Pre-Qualified” could lead consumers to believe that everyone gets pre-qualified, when you really mean “Apply for Pre-Qualification” (not that everyone will be approved). Unintentionally, you may have committed an Unfair, Deceptive or Abusive Acts or Practices (UDAAP) violation.
 
Remember that your posts and ads are published on behalf of a business with strict compliance rules, so say what you mean, don’t be misleading and don’t forget the disclosures!

4. Beware of Rogue Posts
Every credit union wants its employees to be enthusiastic about their institution and to encourage new members and new business. But when that carries over to employees’ personal social media accounts, it could be troublesome. Employees may inadvertently “advertise” on their personal accounts and violate a regulation in the process.

Your credit union should establish a clear policy that requires employees to submit any credit union-related posts in advance for review or that simply does not allow employees to post on behalf of or about the credit union. Your policy should also address employees sharing credit union posts or ads and what personal commentary can or cannot be included.

Social media is a great way to reach current and potential members and you should absolutely make the most of it. Just keep in mind that the same regulations apply whether you’re creating a website ad or a social media post and reference these tips to stay in compliance while giving your marketing team room to be creative.
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Looking for help keeping your social media accounts in compliance? ViClarity's expert audit team provides website and social media reviews. Contact our team to learn more or schedule a review.

Providing compliance support at no additional cost to our members in the Dakotas, ViClarity will deliver! With their expertise in governance, risk, and compliance consulting solutions for credit unions, they can be relied on to help you with any compliance question!