Last week, we discussed how your web hosting provider can ensure your bank or credit union website is compliant with federal examiners. In the conclusion of the series, we’ll look at the regulatory requirements affected by the design of your website.
Advertising Requirements and Disclosures
Your credit union website is as much a marketing tool and advertising medium as the more traditional forms of advertising. As such, it must include the advertising requirements, notices, and member disclosures required by the Real Estate Settlement Procedures Act (RESPA), Truth in Lending (Regulation Z), and Truth In Savings (Regulation DD) and Fair Housing regulations.
Your web designer and developer can create specific web pages for disclosures, agreements, and notices along with a link to a PDF for your members to download. As long as you obtain the member’s consent to provide these documents electronically under the Electronic Signatures in Global and National Commerce Act (E-Sign Act), you can satisfy several regulations, including the ones listed above.
A design element you don’t want to overlook on your website is clearly presenting the proper FDIC or NCUA insurance notices to disclose the coverage level and risks of certain types of products you offer. This includes displaying the proper logos and verbiage required by the entities as well as providing the appropriate links for your members’ convenience.
The Federal Financial Institutions Examination Council (FFIEC) also recommends to include the following information on your website for your members:
- Main office and branch office locations
- Contact information for member service
- Procedures for filing complaints and reporting issues
Designing your website with these guidelines in mind will lessen compliance and legal risks for your financial institution.
Web Accessibility and ADA Compliance
In an earlier blog, we stressed the importance of having a credit union website that is compliant with the Americans with Disabilities Act (ADA). The ADA and Section 508 of the Rehabilitation Act of 1973 require website content to be accessible for all people. This includes financial institutions, which the ADA categorizes as a service establishment.
Designing your website for accessibility involves several factors, such as the colors you use, the organization and structure of individual pages and the overall site, and proper use of alt text and captions for images. You can find more guidelines for writing, designing, and developing an ADA-compliant credit union website on the World Wide Web Consortium (W3C) website. Lastly, you’ll need to post your institution’s accessibility statement or policy on your website.
If your bank or credit union doesn’t meet these standards, you’re putting yourself at risk for litigation. ADA lawsuits have steadily risen over the years as disabled members conduct more business transactions online. Some attorneys and their clients will even go out of their way to actively find financial institutions to sue for having a non-compliant website.
Designing your credit union website with accessibility in mind isn’t just the law. You’ll also be able to maintain and attract more members as well as optimize user experience for everyone.
Final Words
Annual compliance examinations can be stressful, and you don’t want to overlook your website. CUWebsite™ Services has worked with community banks and credit unions for more than two decades. We understand the importance of compliance, and our team can design your site to meet government regulations. We also have an ADA Accessibility Module to prevent your bank or credit union from accessibility litigation. Don’t wait until the last minute to bring your website up to regulatory and legal compliance.
