Credit union video with Reg DD disclosures built in
Put an APY on screen and a 20-second reel becomes a compliance artifact. A disclosure layer that survives re-edits, plus a member story that never triggers.
Hold an APY on screen for six frames and you have changed what the video is. Before that frame it was a brand reel. After it, it is an advertisement for a deposit account, and Truth in Savings now requires it to carry a specific set of facts — minimum balance to obtain the yield, minimum opening deposit, whether the rate is variable, how long the offer stands, whether fees can reduce earnings. Nobody at the credit union decided this. A number on a title card decided it.
Marketing teams usually discover this the third time legal sends a reel back, and the fix they reach for is the wrong one: burn the disclosure into the exported MP4 and never touch the file again. That works exactly until the rate changes, and on a share certificate the rate changes whenever the board moves it. Then the whole thing gets rebuilt from scratch.
There is a better shape. Treat the disclosure as a separate layer on a timeline you keep, and treat member stories as a second, parallel format that is built specifically to never trigger anything at all.
What actually pulls the trigger
The rules that matter split cleanly by product. Deposit products fall under Truth in Savings — the CFPB's Regulation DD for banks, and NCUA's Part 707 rule for federally insured credit unions, which covers the same ground. Loan products fall under Truth in Lending, Regulation Z. Both work the same way: say one thing, and you owe a list of others.
| What appears on screen or in the VO | What it drags in |
|---|---|
| A rate of return on a deposit account | It must be stated as an annual percentage yield using that term, plus the accompanying Truth in Savings ad disclosures |
| An APY on a share or certificate | Minimum balance to obtain it, minimum opening deposit, variable-rate status, the period it is offered, effect of fees on earnings |
| A term-account APY | Early withdrawal penalty language |
| A stated bonus or cash offer | The APY, the minimum balance and time to qualify, when the bonus is paid |
| A loan payment amount, number of payments, or down payment figure | The Reg Z closed-end trigger disclosures, including the APR |
| A dollar finance charge | Same Reg Z set |
Two practical notes an operator learns the hard way. First, the APR on its own is not a Reg Z trigger term — you can say "rates from X% APR" without opening the disclosure box, but the moment you add "$249 a month" you have. Second, the official advertising statement for federally insured credit unions has media-based exemptions written for radio and television spots. A vertical social video is neither of those things in any obvious sense, and betting the examination on that reading is a poor use of a good compliance department. Put the statement in.
Build the disclosure as a layer, not a burn-in
The version that survives is a timeline you keep and re-render, not a file you export and archive. The Versely editor is EDL-based: one project holds the clips, the caption track, the overlays, and the timing, and you re-render it when any piece changes. That is the difference between a rate update costing ten minutes and costing a shoot.
The structure that has held up:
- Track 1 — visuals. Branch b-roll, member footage, generated abstract backgrounds. Never contains text.
- Track 2 — the offer card. The APY, the term, the product name. One overlay, one text field, one place to change a number.
- Track 3 — the disclosure block. A timed text overlay that appears with the offer card and stays for its full duration, not a flash card at the end.
- Track 4 — the standing statement. Insurance statement and equal housing mark where applicable, persistent, bottom-safe.
Save the finished arrangement as a reusable draft named for the product, not the campaign. "Share certificate — 12mo" outlives "Q3 Savings Push," and next quarter's job is swapping two numbers rather than rebuilding four tracks.
Legibility is where these fail review, not accuracy. Disclosure text is small by nature, and platform UI eats the bottom third of a vertical frame. Render a free 480p preview, which carries a short per-user cooldown between passes, then read the disclosure on a phone at arm's length before anything gets charged. The full-resolution export is billed once, regardless of how many clips the timeline contains. The safe-zone guide makes the case that no single safe percentage holds across platforms or formats, so pull the current template from each surface you post to — and in every one of them, the bottom of a vertical frame is the tightest margin, because that is where the caption rail and the action buttons cluster.
One more thing worth knowing before you commit to a look: generated video models still render small text unreliably. Any disclosure that matters should be an editor overlay composited over the footage, never text you asked a video model to produce.
The format that never triggers: member stories
The disclosure layer solves rate content. It does not make rate content good. A share certificate APY is a commodity claim that a rate-comparison site will always beat you on, and the reason members join a credit union in the first place is not visible in a number.
Member stories are the format built to avoid triggering entirely, because they contain no rate, no payment, no bonus, and no term. Their structure:
- 0:00–0:03 — the member, in their own words, naming the moment. "The truck died on a Tuesday."
- 0:03–0:15 — what happened next, told at the level of the human interaction. A name, a branch, a phone call answered. No product name, no numbers.
- 0:15–0:22 — the outcome, again without figures. "I was driving Thursday."
- 0:22–0:25 — a plain close. "Talk to someone who knows your name." Nothing that reads as an offer.
That script carries no Truth in Savings or Reg Z obligations because it makes no rate, payment, or bonus statement. It still needs the usual care: a signed release from the member, no implied endorsement of a specific product, and no claim about approval likelihood. But it is the closest thing this category has to content you can publish the same week you shoot it.
Shoot these in the branch on a phone, three at a time, and use auto captions rather than subtitles baked by hand — member interviews run long on syllables and short on clean audio, and readable captions do more for completion than any edit you will make.
The production loop
A two-person marketing team can run this weekly.
- Monday — check the rate sheet. Any product whose rate moved gets its saved draft opened and two fields updated.
- Tuesday — preview and route. 480p passes to compliance with the disclosure legible on a phone screenshot. Approvals happen against the preview, not the export.
- Wednesday — export and schedule. One charge per finished video, captions applied from the brand preset so every asset looks like the same institution.
- Ongoing — one member story a fortnight. These are the assets that actually get shared, and they are the reason the rate content has an audience to land in front of.
The credit union page covers what the rest of the stack looks like. If your lending side runs its own content calendar, the mortgage and lender playbook handles the Reg Z side in more depth.
FAQ
Does a 20-second Reel really need the full disclosure?
Duration does not exempt an ad from Truth in Savings. The official advertising statement has exemptions tied to media type, including radio and television spots below a length threshold. Those were written for broadcast, and applying them to social video is an argument you do not want to be having during an examination. The practical answer used by most compliance teams: if the video states a yield, the disclosures ride with it, and if the disclosures will not fit legibly, the video should not state a yield.
Can we put the disclosures in the caption instead of on screen?
Ask your compliance counsel, and expect them to say no for anything load-bearing. Captions are truncated by every platform, editable after posting, stripped when the video is downloaded and re-shared, and absent entirely when the clip plays in a feed preview. On-screen disclosure travels with the file. Post copy is a supplement, not a substitute.
How do we handle a rate that changes mid-campaign?
That is the entire argument for the layered timeline. Open the saved draft, change the APY field and the matching figures in the disclosure block, preview, export. Scheduled posts referencing the old asset get swapped. If the video is already live and the rate has moved, take it down rather than leaving it up with a stale figure — an advertisement stating a yield the institution no longer offers is a worse problem than a gap in the calendar.
Should member stories use generated footage?
Not for the member. A generated face presented as a real member is a fabricated testimonial, and that is a much larger problem than a disclosure miss. Generated video is useful in this category for the things nobody expects to be documentary: abstract brand backgrounds, motion behind a rate card, seasonal b-roll. The b-roll generator covers that job well. The person on camera should be a person.
Start with one product. Open the video editor, build the four-track disclosure layer once for your most-advertised certificate, and save it as a draft — every rate change after that is a two-field edit.