Letter to the NCUA on the Proposal to Streamline Advertising Regulations

The American Bankers Association (ABA) appreciates the opportunity to comment on the National Credit Union Administration's (NCUA) proposal to streamline its regulations governing advertising and the notice of insured status under 12 CFR Part 740. The proposal would remove the requirement to include an official advertising statement in credit union advertisements while retaining requirements related to the display of the official sign at locations where deposits are usually and normally received.

ABA is puzzled by the NCUA’s direction given the emergence of financial services providers offering deposit like products. In fact, the FDIC recently updated its signage rules to make clear what is and is not insured across digital and traditional banking spaces. To avoid consumer confusion, ABA urges the NCUA to align its approach with FDIC’s recently modernized framework.

ABA supports regulatory approaches that reduce prescriptiveness and encourage innovation while preserving clear, consistent insured‑status signals across charters. Following adoption of its 2023 final rule, the FDIC adjusted the Part 328 digital signage framework—delaying compliance dates and refining placement expectations to focus on the pages and screens most relevant to consumers—thereby easing implementation while preserving the integrity of deposit‑insurance messaging. Aligning NCUA’s approach with FDIC’s calibrated framework would minimize divergence across digital and traditional channels where consumers routinely encounter bank and credit union messages.

Download the comment letter to read the full text.