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November 29, 2011

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Joyce

Can I clarify something? Sorry...sometimes clarifications give rise to more questions. I agree that 740.4 states we must use the official SIGN (found under 740.4(b)) on the Internet page were we take deposits or open accounts (in our case on our Internet Banking page). But our MAIN Internet page (aka home page) is permitted to just have the official STATEMENT if we choose in accordance with 740.5(a). Is this correct? I prefer to use the SIGN but we're having graphic issues right now and we're just using the statement but the majority wants to retain just using the statement even after the graphic issue is fixed.

Steve Van Beek

Joyce,
This is an important distinction - I'm glad you brought this up. Today's post was not accurate in using the term "main Internet page" when discussing the requirements of 740.4(b).

You are right that 740.5(a) includes the requirement for the "official advertising statement" on the main Internet page. The credit union could use any of the three options on its main Internet page - provided that page is not one where members can deposit funds or open accounts. If members can deposit funds or open accounts from the main Internet page, the requirement from 740.4(b) would kick in.

Keep in mind that even though the official sign wouldn't be required in your situation, it might be a situation where members (and examiners) are used to seeing the official sign used on the main Internet page.

Kristie Kenney

Please help clarify something... Is the "official sign" required to be displayed at the night depository? Is the "official sign" required to be displayed at a Credit Union's ATM that accepts deposits?

Steve Van Beek

Kristie,

Section 740.4(e) of NCUA's regulations indicates "automatic teller machines" are excluded from the requirement for the official sign. Night depositories are a bit more complex and we'll discuss in a future blog post.

Kirsten Younkin

Can I get Steve Van Beek email address?

Jason Goodman

Is the "Official Sign" required at each drive-thru teller station outside or can they be posted at each station on the window of the branch building facing the car lanes?

Steve Van Beek

Jason,
I haven't seen clarification from NCUA on this issue. The regulation states "at each station or window." You'd have an argument that you have only one window. However, the counterargument is that you have two (or more) "stations".

Unless NCUA provides some clarity, it is a business decision. The conservative approach would be to provide the Official Sign at each station.

Julie Reinoso

Steve, what if we have a drive thru in which there is not teller window facing the cars? Is putting the NCUA sticker on the tubes sufficient?

Steve Van Beek

Julie,
Great question - you'd have a pretty good argument that putting the NCUA sticker on the tube would meet the "at each station" test.

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