“There are some compliance pitfalls, and we do a lot of training for various leagues and for credit unions specifically on social media compliance issues because it's a big area of concern,” said Gaye DeCesare, president/CEO of COMPASS 4 CUs LLC., a Woodbridge, Va.-based compliance services company.

Some of the less-than-obvious pitfalls are around unfair, deceptive and abusive acts or practices.

The Dodd-Frank Act of 2010 defined UDAAP as acts or practices that financially harm consumers and interferes with a consumer's ability to avoid financial harm.

For credit unions, that means they have to be careful with how they word their social media promotions.

“It's always kind of a fine line, but we’ll see something like, ‘we’ll beat the competition’ for a car loan ad,” DeCesare said.

A credit union can get into trouble with that wording because it's questionable whether they will always beat the competition, or if it will have a rate that's better than the 0% financing offered at dealerships.

“Sometimes we’ll see credit unions say that all of your friends and family can join, but more often than not, that isn't the case because they have a restricted field of membership,” DeCeasare explained. “We’ll also see wording like ‘prequalified’ or ‘get preapproved before shopping for your next car,’ but not everyone can be preapproved because of credit problems. We should reword that promotion to say ‘apply for preapproval’ or something like that. We see a lot of credit unions getting into trouble making statements like these that are a little bit hyperbolic, I guess.”

Another issue that gets credit unions into trouble is featuring photos with promotions that fail to show diversity.

“You want to make sure that you are not giving the impression of preferring one group or something like that,” she said. “So you don't want your pictures only showing young white couples.”

Photos should feature a mix of races, ages and genders. Even if your credit union's employees and members are 95% white, DeCeasare said credit unions still need to post images that show diversity.

Discrimination issues can surface in other areas as well.

Todd Pietszch, public relations manager for the $14.4 billion BECU in Tukwila, Wash., works on a social media team that develops campaigns for the state's largest credit union. In developing a sponsorship social media promotion for a local RV show, Pietszch said the credit union offered free admission to its members. But the social media team learned it couldn't offer free admission to members who only had a credit or debit card.

“From a compliance perspective, you can't do that because some members don't have a credit or debit card,” Pietszch said. “So we had to add words that would allow members to show a statement or some other proof of membership to get free admission.”

So while Pietszch encouraged credit unions to develop a strong relationship with compliance officers, he said it's also important to provide them with all the details of a social media marketing campaign to prevent compliance problems.

Compliance problems can also easily surface when credit unions don't pay attention to the rather complex details of trigger terms that always require disclosures.

For example, a specific interest rate is a trigger term that requires compliance disclosures due to Truth in Savings regulations. If a credit union decides to promote a rate for a share account or certificate, it can use “APY” but must also include the words “annual percentage yield” at least once.

Other required disclosures include statements about rate changes, fees that may reduce earnings, the minimum balance and the duration of the rate.

In terms of posting an interest rate for a loan product, under Regulation Z, credit unions must also use “APR” and “annual percentage rate.”

Some credit unions circumvent these requirements by not listing a rate for a loan, for example, and using general statements such as, “come check out our low auto loan rates,” DeCesare said.

Open-end and closed-end loans also have a variety of trigger terms and rules that credit unions must review with compliance officers to avoid any delays in launching social media marketing campaigns.

For example, for a closed-end loan, a trigger term is the number of payments or the repayment period, such as 48 months for a car loan or 20 years for a mortgage loan. For open-end loans such as credit cards, listing the APR requires disclosures of fees and a statement that the rate may change.

The good news is credit unions don't need to include all of these disclosures in a social media post. They do, however, have to include a hyperlink that takes members to a landing page with all of the required disclosures, DeCesare said.

However, there is no one-click rule for credit unions marketing an insured share account. That promotion must feature the official NCUA logo or the statement that the credit union is federally insured by the NCUA. And when a credit union advertises mortgages, the equal housing logo or the statement “equal housing lender” must be included.

Even compliance experts agree that all of the rules and regulations can be complex and confusing, and are not particularly conducive to social media marketing.

NAFCU is currently making efforts to change the rules to give credit unions more flexibility.

In December 2013, the Federal Financial Institutions Examination Council issued guidance regarding social media and its effect on consumer compliance and risk management.

“While the FFIEC guidance was useful to credit unions, NAFCU continues to hear from our members that applying Part 740 to social media is unclear, complicated and burdensome,” NAFCU wrote in a letter to the NCUA last year. “NAFCU and our members believe these rules should be amended with the use of social media in mind to include more flexibility as opposed to the rigidity of the current rules.”

Alexander Monterrubio, NAFCU's director of regulatory affairs, said the national organization continues to address the issues of Part 740 and noted that the regulations are up for review by the federal agency this year.

However, because the NCUA board is undergoing leadership transitions this year and a new president will be in charge of appointing board members starting in 2017, it's uncertain whether there will be any modifications to Part 740.