ARLINGTON, Va.–In a comment letter to NCUA on its proposed rule on Accuracy of Advertising., NASCUS said it supports the plan but also urged the agency to craft rules flexible enough to accommodate emerging social media platforms.
NASCUS said it further agrees that NCUA should expand its exemption of television and radio advertisements from 15 seconds to 30 seconds or less, as is currently proposed.
“We also note that the official statement exemption of Part 740.5 refers explicitly to radio and television advertisements,” NASCUS said in its letter. “We recommend NCUA consider more flexible language that could be adopted for future developments in commercial delivery platforms. For example, NCUA should consider clarifying the exemption applies to radio, television, and other similar mediums.”
NASCUS said it also supports withdrawing the 2011 requirement that credit unions include the official statement on conditions of report required to be filed by law.
The trade group added that while there are now three versions of an official advertising statement, it believes the agency should authorize a fourth version that simply states, “Insured by NCUA” in order to meet the limitations of social media.
“As NCUA aptly acknowledges in its request for comments on reconciling advertising rules with emerging social media platforms, the flexibility for credit unions to utilize a minimum amount of characters, while conveying the important message of federal share insurance, will be essential in the marketplace of the future,” NASCUS said.
It also urged consideration of the following allowances for social media advertising:
- NCUA rules should distinguish between messages appearing on the credit union’s own social media sites as opposed to advertising that might appear on the site of a third party.
- NCUA rules should clarify that inclusion of the official advertising statement on the credit union’s masthead or on the credit union’s landing page for its social media sites satisfies the regulatory requirements rather than the official statement having to appear on every page.
- NCUA rules should allow the official advertising statement to appear by link, no more than one click away, to a social media posting.
“Given the evolving nature of social media, NASCUS also recommends that NCUA commit to regularly reviewing the advertising rule to consider new developments and new technology,” wrote NASCUS EVP and General Counsel Brian Knight in the letter.