DoD Financial Management Regulation and The Promotion of Bank Product and Services
The DoD Financial Management Regulation has two sections that pertain to military banking – Advertising and Financial Education.
The rules vary for each area. The language at DoD FMR 330304 clearly allows on-base banks to advertise, including “identifying the financial services that are available on the installation.”
A. An on-base financial institution may use the unofficial section of that installation’s daily bulletin, provided space is available, to inform DoD personnel of financial services and announce seminars, consumer information programs, and other matters of broad general interest. Announcements of free financial counseling services are encouraged. Such media may not be used for competitive or comparative advertising of, for example, specific interest rates on savings or loans.
B. An on-base financial institution may use installation bulletin boards, newsletters, or web pages to post general information that complements the installation’s financial counseling programs and promotes financial responsibility and thrift. Message center services may distribute a reasonable number of announcements to units for use on bulletin boards so long as this does not impose an unreasonable workload.
C. An on-base financial institution may include an insert in the installation’s newcomers package (or equivalent). This insert should benefit newcomers by identifying the financial services that are available on the installation.
D. DoD Manual 5120.20 prevents the use of the Armed Forces Radio and Television Service to promote a specific financial institution.
E. Off-base financial institutions are not permitted to distribute competitive literature or forms on the installation. These institutions, however, may use commercial advertising, mailings or telecommunications to reach their customers.
F. Advertising in government-funded (official) installation papers is not permitted with the exception of insert advertising in the Stars and Stripes overseas. Installation newspapers funded by advertisers are not official publications and, thus, may include advertising paid for by any financial institution.
G. Installation activities, including Military Exchange Services and concessionaire outlets, shall not permit the distribution of literature from off-base financial institutions if there is an on-base financial institution. This does not prevent the Military Exchange Services from distributing literature on affinity credit card services that those Military Exchange Services may acquire centrally through competitive solicitation.
When it comes to financial education. There are some limits on the extent to which it can be used to promote banking services. Those limits appear below.
330309. Financial Education
A. Officials of on-base financial institutions shall be invited to take part in seminars to educate personnel on personal financial management and financial services. Financial institutions shall be encouraged to provide financial education and counseling services as an integral part of their financial service offerings. Officials of on-base financial institutions shall submit advance briefing texts for approval by the installation commander to ensure that the program is not used to promote the services of a specific financial institution.
The rules boil down to the idea that on-base financial institutions can’t promote their services to “captive audiences” in financial education contexts. The bank may, however, advertise and provide free financial counseling in which they suggest specific financial products and services. To assist in defining the line between off-base and on-base financial institutions in the area of advertisement, sponsorship, and education, below is the link to the DoD Instruction governing Personal Commercial Solicitation on DoD Installations. Note that the limitations about promoting specific products and services in the context of financial education is also included here at paragraph 220.127.116.11.