2014 Virginia Credit Union League Spring Compliance Conference

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1 2014 Virginia Credit Union League Spring Compliance Conference Bonuses, Gambling, Promotions & Sweepstakes Daniel C. Summerlin III & Nicholas V. Albu Woods Rogers PLC

2 DISCLAIMER THIS PRESENTATION IS INTENDED TO PROVIDE GENERAL LEGAL INFORMATION AND SHOULD NOT BE CONSTRUED AS LEGAL ADVICE BY OR ON BEHALF OF THE AUTHORS, PRESENTERS OR VIRGINIA CREDIT UNION LEAGUE. THIS PRESENTATION IS NOT INTENDED TO COVER EVERY CONCEIVABLE ISSUE RELATED TO THE TOPICS DISCUSSED. RATHER, THE SPECIFIC FACTS THAT APPLY TO YOUR PARTICULAR SITUATION MAY RESULT IN A DIFFERENT OUTCOME THAN ANTICIPATED BY THE INFORMATION AND EXAMPLES PROVIDED. YOU SHOULD CONSULT WITH AN ATTORNEY FAMILIAR WITH YOUR PARTICULAR FACTS, ISSUES AND APPLICABLE LAWS.

3 2014 Virginia Credit Union League Spring Compliance Conference Authority for Marketing and Promotional Activities

4 Federal Credit Unions Certain activities are pre-approved under the Federal Credit Union Act as incidental powers necessary to effectively carry on business Incidental power activities are convenient or useful to carry out business; are the functional equivalent or outgrowth of a credit union s business activities; and involve risks similar to those already assumed as a part of credit union s business

5 Federal Credit Unions (cont d) Marketing activities are pre-approved as an incidental power activity Marketing activities promote credit union membership promote products & services to members may include advertising may include raffles and membership referral drives List of examples under FCU Act is not exclusive or exhaustive

6 Federal Credit Unions (cont d) Marketing power to service non-members may be permissible, but in a limited fashion Non-member marketing activities cannot become a substitute for membership Examples of permissible marketing services to non-members may include limited wire transfers for non-members to promote membership and familiarize users with the benefits of membership coin sorting services for non-members to promote membership

7 State Credit Unions Virginia state chartered credit unions have authority to conduct activities relating to the purposes of the credit union as its charter or bylaws may authorize As long as those activities are not inconsistent with Virginia law or the credit union s bylaws or charter, marketing activities are likely permissible

8 2014 Virginia Credit Union League Spring Compliance Conference Virginia and Federal Law Concerning Promotions

9 Virginia s Illegal Gambling Law Illegal gambling means making, placing or receiving a bet or wager of anything of value in exchange to win anything of value the outcome of which is dependent on the result of any game, contest or event whose outcome involves chance Illegal gambling is a crime under Virginia law The key is exchange of consideration (money or something else of value) for chance to win

10 Illegal Gambling Examples Raffle or lottery in which members purchase $1.00 tickets for chance to win car Sweepstakes requiring $5.00 entry fee for opportunity to win $1,000 prepaid debit card

11 Sweepstakes Sweepstakes are typically random drawings for prizes Sweepstakes involve chance, and an opportunity to win a prize Sweepstakes do not involve the element of consideration (money or something else of value) in exchange for chance to win

12 Legal Sweepstakes v. Illegal Gambling Ultimate question is whether the sweepstakes is a product (pay to play game of chance) or a legitimate means to promote services The question often turns on a complicated analysis of whether consideration is present For example Sweepstakes as a marketing tool to promote a credit union membership campaign versus Sweepstakes as subterfuge to sell product under guise of marketing tool

13 Deceptive Mail Prevention and Enforcement Act Purpose of the Act is to establish consumer protections to prevent deceptive mailings Think: Publishers Clearing House The Act Imposes requirements on sweepstakes sent through the mail Requires clear and conspicuous disclosures regarding contest terms, odds of winning etc Also requires an opt-out disclosure

14 Federal and Virginia Telemarketing Law Promotions utilizing telemarketing solicitation should comply with Federal and Virginia law Virginia prohibits unwanted telephone solicitation offering or advertising goods or services Violators of Virginia law may be subject to damages, attorney s fees and costs and civil investigation and penalties by the Commonwealth The federal Telephone Consumer Protection Act and the Telemarketing Sales Rule may also apply and give rise to additional damages

15 CAN-SPAM Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM) Promotions via may be required to be labeled as advertisements or solicitations and include opt-out instructions Prohibits use of deceptive subject lines and false headers Key consideration is whether the contains commercial content (or has a primary commercial purpose) triggering CAN-SPAM requirements

16 COPPA Children s Online Privacy Protection Act (COPPA) The Act pertains to collection, use or disclosure of personal information collected from children through the internet Applicable if the credit union maintains a website or other online service directed to children or has actual knowledge that it is collecting or maintaining personal information from children If COPPA is triggered, the credit union promotion should abide by parental consent procedures

17 2014 Virginia Credit Union League Spring Compliance Conference Other Considerations in Promotional Advertising

18 TIS Disclosures for Bonuses A bonus is an award or other consideration worth more than $10 given or offered to a member during a year in exchange for opening, maintaining or renewing an account, or increasing an account balance For bonuses, credit unions must disclose (beforehand) the amount or type of any bonus when the bonus will be provided, and any minimum balance and time requirements necessary to obtain the bonus

19 TIS Disclosures for Bonuses (cont d) If a bonus is stated in an advertisement, the advertisement must clearly and conspicuously state the following (if applicable) (i) Annual percentage yield (using that term) (ii) Time requirement to obtain the bonus (iii) Minimum balance required to obtain the bonus (iv) Minimum balance to open the account, if greater than the minimum balance to obtain the bonus; and (v) Time when the bonus will be provided

20 TIS Disclosures for Bonuses (cont d) Exception for certain media No requirement to disclose (iv) and (v) above if the bonus advertisement is made through broadcast or electronic media (i.e., tv or radio) outdoor media (i.e., billboards) telephone response machines

21 TIS Disclosures for Bonuses (cont d) Exception for indoor signs No requirement for bonus advertisement disclosures if the bonus advertisement is made through signs inside credit union premises, as long as signs state the rate as an annual percentage yield using that term or APY (with certain limited exceptions), and contain a statement advising members to contact an employee for further information about applicable fees and terms

22 TIS Disclosures for Bonuses (cont d) Exception for newsletters No requirement for bonus advertisement disclosures if the bonus advertisement is made through newsletters, as long as newsletters state the rate as an annual percentage yield using that term or APY (with certain limited exceptions), and contain a statement advising members to contact an employee for further information about applicable fees and terms

23 1099 Reporting Requirements An IRS 1099 form reports other sources of income not included on a W-2 form Credit unions should use 1099 forms to report payments to members Payments include prizes and awards, cash or otherwise Value of non-cash items are determined by fair market value (FMV) of the property Interest/dividend reporting is a 1099-INT issue Other taxable income is a 1099-MISC issue

24 1099 Reporting Requirements (cont d) Dividends/interest refers to a dollar amount paid in compensation for the use of money Any interest totaling $10 or more per year must be reported to the IRS and the bonus recipient Dividends/interest include bonuses (cash or FMV) given as inducement to members either to open an account, or add to an existing account With certain exceptions for de minimus amounts, these bonuses must be reported on a 1099-INT form

25 1099 Reporting Requirements (cont d) In addition to reporting bonuses on for 1099-INT, credit unions are required to report other payments to members on form 1099-MISC Payments include prizes and awards, cash or otherwise, if greater than or equal to $600 Just like reporting property on a 1099-INT, value of non-cash items for purposes of a 1099-MISC are determined by FMV of the property The 1099-MISC reporting requirement also applies to non-members, such as winners of a credit union promotion that is open to the public

26 Official Promotion Rules Credit Unions should establish all terms and conditions for the promotion for example: No purchase necessary Void where prohibited Purchase and membership not required Eligibility and entry requirements Entry instructions Winner selection & odds of winning Prizes and their value

27 Official Promotion Rules (cont d) Where to obtain rules and list of winners General conditions and disclaimers Credit Unions should also establish a short-form of the official rules At minimum, this should include all advertising disclaimers required by law May be used in advertising through print, broadcast, radio, mail etc Credit Unions should also require a prize acceptance and release agreement from winners releasing the credit union from certain liabilities

28 Internet Promotion Considerations If a credit union offers a promotion through the its website or over the internet, geographical restrictions on participation are important If a promotion is open to residents of other U.S. states or foreign countries, the promotion may be subject to the laws of those jurisdictions The official rules for online promotions should address matters such as technical difficulties or other issues that may affect entries

29 2014 Virginia Credit Union League Spring Compliance Conference Questions? Please contact Daniel C. Summerlin III at or Nicholas V. Albu at

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