What NCUA, ADA, and UDAAP Actually Require for Your Credit Union Website

Credit union websites operate under overlapping federal regulations that differ meaningfully from bank requirements. Understanding which rules apply—and how they interact—prevents both compliance failures and over-compliance that hampers marketing effectiveness.

NCUA Truth in Savings (12 CFR Part 707) governs how credit unions advertise deposit accounts. When you mention rates in any promotional context, specific disclosure requirements trigger automatically. This includes website banners, landing pages, blog posts discussing products, and even social media content that links back to rate information.

ADA Title III and WCAG Standards require that credit union digital services be accessible to members with disabilities. While no federal regulation explicitly mandates ADA Title III applies to credit union websites; [ADA Title III website standards](/resources/banks/bank-website-ada-accessibility-seo) is the current accessibility benchmark, this standard has emerged as the practical compliance benchmark through DOJ guidance, settlement agreements, and court decisions. Credit unions as "places of public accommodation" fall under Title III coverage.

CFPB UDAAP Authority prohibits unfair, deceptive, or abusive acts and practices in consumer financial marketing. For credit unions, this means marketing claims must be substantiated, material terms cannot be buried, and the overall impression of promotional content cannot mislead even sophisticated readers.

Note: This content provides general regulatory guidance. Specific compliance requirements vary by charter type, state, and individual circumstances. Verify current requirements with your compliance officer and legal counsel.

The Truth in Savings regulation creates specific disclosure triggers whenever credit unions advertise deposit accounts. These aren't suggestions—they're mandatory formatting and content requirements that NCUA examiners actively review.

When APY Disclosures Trigger

• Any advertisement stating a rate of return (including "competitive rates" or "great rates" language)
• Bonus or promotional rate mentions
• Comparison statements about your rates versus competitors
• Time-limited rate offers

Required Disclosure Elements

When triggered, advertisements must include the Annual Percentage Yield using that exact term (not just "APY" without context), minimum balance requirements to earn the stated APY, minimum opening deposit if different from the balance requirement, and any fees that could reduce earnings.

Proximity and Prominence Rules

Disclosures must appear in close proximity to the rate claim—not buried in footer text or behind a "see details" link. The regulation requires disclosures be "clear and conspicuous," which NCUA interprets as similar font size, visual accessibility, and placement that a member would naturally see when viewing the rate.

Website-Specific Considerations

For web pages, each page containing rate information needs appropriate disclosures on that page. Linking to a single disclosure page doesn't satisfy the proximity requirement. Rate tables, comparison tools, and promotional banners each need their own compliant disclosure structure.

Digital accessibility compliance requires structural website changes—not plugin installations. Accessibility overlay tools have faced significant legal challenges and often create new compliance problems while failing to address underlying issues.

WCAG 2.2 Level AA: The Practical Standard

While ADA Title III doesn't specify technical standards, WCAG 2.2 Level AA has become the de facto compliance benchmark. Key requirements include:

• Perceivable: Text alternatives for images, captions for videos, sufficient color contrast (4.5:1 for normal text), content readable without style sheets
• Operable: Full keyboard navigation, no content causing seizures, skip navigation links, descriptive link text (not "click here")
• Understandable: Readable language declarations, consistent navigation, error identification and suggestion in forms
• Robust: Valid HTML, ARIA labels where appropriate, compatibility with assistive technologies

Common Credit Union Website Failures

In our experience auditing financial services websites, recurring issues include PDF documents without text alternatives (rate sheets, disclosures, applications), form fields without proper labels, rate calculators that don't work with screen readers, and authentication processes that rely solely on visual CAPTCHAs.

Testing Requirements

Automated scanners catch roughly 30-40% of accessibility issues. Manual testing with actual assistive technologies—screen readers, keyboard-only navigation, voice control—identifies problems automated tools miss. Many credit unions benefit from engaging members with disabilities for usability feedback.

UDAAP violations don't require intent. Credit union marketing that creates misleading impressions—even through omission or emphasis—can trigger enforcement actions regardless of whether the underlying product is fairly structured.

Deceptive Practices in Digital Marketing

The CFPB considers marketing deceptive when it includes representations or omissions likely to mislead consumers acting reasonably under the circumstances, and those representations are material to consumer decisions. For credit unions, this commonly surfaces in:

• Rate advertisements emphasizing promotional rates without adequate disclosure of standard rates
• "Free" claims for accounts with conditional fee waivers
• Comparison advertising that cherry-picks favorable metrics
• Testimonials or reviews that don't reflect typical member experiences

Unfair Practices to Avoid

A practice is unfair when it causes substantial injury to consumers, the injury isn't reasonably avoidable, and the injury isn't outweighed by countervailing benefits. Website structures that make it difficult to find fee disclosures, opt-out mechanisms that require excessive steps, or application flows that obscure material terms can all constitute unfair practices.

Abusive Practices

This standard targets practices that take unreasonable advantage of consumers' lack of understanding, inability to protect their interests, or reasonable reliance on the credit union to act in their interest. Given credit unions' member-owned structure, CFPB scrutiny of abusive practices may focus on whether marketing exploits the trust associated with cooperative ownership.

Use this checklist as a starting framework for compliance review. Specific requirements may vary based on your credit union's charter, state laws, and product offerings. Review with your compliance officer before implementing changes.

Truth in Savings (12 CFR Part 707)

• All rate advertisements include APY with that exact terminology
• Minimum balance requirements appear in same visual field as rates
• Minimum opening deposits disclosed when different from balance requirements
• Fee impacts on earnings disclosed for all advertised accounts
• Promotional rate terms include duration and post-promotion rates
• Rate comparison claims are substantiated and current

ADA/WCAG 2.2 Level AA

• All images have descriptive alt text (including rate graphics)
• Video content includes captions and transcripts
• Color contrast meets 4.5:1 ratio for text
• Site fully navigable via keyboard only
• Form fields have visible, associated labels
• PDFs are tagged and screen-reader accessible
• Error messages identify specific problems and services

UDAAP Marketing Standards

• Material terms not buried in fine print or behind clicks
• "Free" claims accurately reflect account conditions
• Testimonials represent typical member experiences
• Comparison advertising uses current, verifiable data
• Promotional emphasis balanced with standard term disclosure

Compliance gaps rarely exist in isolation. Website issues often indicate broader process problems that affect multiple regulatory frameworks simultaneously. Prioritizing remediation based on risk severity and visibility helps allocate compliance resources effectively.

High-Risk Scenarios

Rate page without Truth in Savings disclosures: This is the most common violation we observe. Remediation requires adding compliant disclosure blocks to every page displaying rates, including dynamically generated rate tables. Timeline: immediate, as NCUA examiners routinely review rate advertising.

Inaccessible online banking login: Authentication barriers affect all members with disabilities and represent significant ADA exposure. Screen reader compatibility, keyboard navigation, and accessible alternative authentication methods require priority attention.

Promotional landing pages with buried terms: UDAAP enforcement has specifically targeted financial institution landing pages where promotional rates dominate visually while material limitations appear in small text. Redesigning information hierarchy reduces enforcement risk.

Medium-Risk Scenarios

PDF rate sheets without accessibility tags, blog posts mentioning rates without disclosures, calculator tools that fail keyboard navigation, and video content without captions all require systematic remediation but typically receive less immediate regulatory scrutiny than primary product pages.

Building Compliance Into Workflow

One-time remediation solves current problems but doesn't prevent recurrence. Integrating compliance checkpoints into content publishing workflows—with specific review criteria for rate mentions, accessibility validation, and UDAAP language review—creates sustainable compliance infrastructure.

For credit unions seeking SEO services that maintain credit union regulatory compliance, implementation must account for these requirements from content strategy through technical execution.