NAFCU has been hearing from members that examiners are conducting website reviews as part of recent examinations. A credit union's website can contain advertising content as well as impact other areas of compliance. Here are some things to consider if conducting a review is on your radar.
Keep in mind that federal regulations define advertisement quite broadly. For example, under Regulation Z, an ad is "a commercial message in any medium that promotes, directly or indirectly, a credit transaction." NCUA's Truth in Savings rule is similarly broad, as is NCUA's general advertising rule. As a result, much of a credit union's website could include content that federal regulation considers to be an advertisement.
From The NAFCU Compliance Blog, written by Brandy Bruyere, Vice President of Regulatory Compliance, NAFCU