Entering Clark County
Sunward's first Nevada branch launch requires both market awareness and a clear path to membership growth. This plan invests $500,000 from June through December 2027 to introduce Sunward across the west valley, reach consumers comparing banking options, and drive new accounts. A mix of digital and traditional media supports three phases: awareness, consideration, and launch. Spending increases and geographic focus narrows as opening approaches, with the largest investment supporting the launch. Media selection reflects each channel's targeting capabilities and restrictions, while measurement progresses from reach and awareness to applications, funded accounts, and branch visits.
Sunward manages more than $4 billion for over 175,000 members in New Mexico, Colorado and California. That is more than any locally based Clark County credit union; One Nevada, the largest, holds $1.5 billion. Anyone can join through free American Consumer Council membership, which Sunward arranges. Awareness media tells the market both things: who Sunward is, and that anyone can join.
The eleven ZIP codes hold 175,582 households and 354,041 adults, about 18 percent of Clark County's population. Local credit unions and national banks already serve them, so every new member switches from another institution. The plan buys channels that can be aimed at this trade area instead of broadcast television, and uses search to reach people already comparing banks.
Google and Meta prohibit ZIP-code targeting for banking ads, so $110,000 of search and social runs on a radius around the branch. Fair lending law bars using a ZIP code as a stand-in for age or race, credit bureau prescreen lists carry firm-offer obligations under federal law, and Nevada restricts geofencing near health care facilities. The plan gives each channel only the targeting its platform and the law allow, and documents why every ZIP is in the buy.
Targeting Within Platform Rules
Two platforms forbid ZIP targeting for banks and credit unions, and that rule shapes everything else in this plan.
No ZIP targeting for consumer finance since February 2024. Covers checking and savings accounts, not only loans. Radius is allowed.
Financial Products and Services category, mandatory since January 2025. No ZIPs, a 15-mile minimum radius, no lookalikes, and the account must be certified first.
Everything except search and social.
Search and social.
Meta's 15-mile minimum radius, drawn to scale. Centered on Summerlin, nearly half of the circle falls over Red Rock Canyon and open desert, so it wastes far less than the same circle drawn anywhere else in the valley.
- Summerlin area
- Established west valley
- Southwest area
- Other ZIPs, denser
- Other ZIPs, less dense
- Desert and parkland, almost no residents
- Meta's 15-mile minimum radius
Estimates from Census ZIP Code Tabulation Area boundaries and ACS 2015–2019 population. The center point is illustrative until the branch address is set.
Meta still allows an uploaded customer list inside the restricted category, which keeps household targeting available where it matters most.
Prescreened audiences from the bureaus turn an ad into a firm offer of credit, with legal duties attached. We build awareness audiences without them.
Defining the Trade Area
The eleven ZIPs group into three tiers, weighted by where households actually live rather than by proximity to the wealthiest part of the footprint. Once the branch address is fixed, any departure from these weights needs a documented reason. Counts are ACS 2020–2024 five-year estimates for the eleven ZCTAs: 175,582 households and 354,041 adults.
43,875 households. It sits closest to any likely branch site but is the smallest of the three areas.
70,401 households, the largest share of the footprint. Residents have long tenure and high homeownership, and the branch is a short drive away.
61,306 households. It is newer, faster-growing and the most diverse of the three. We would plan Spanish-language placements here within existing channel budgets.
Building the Audience
We build all four groups on behavior and property, not age, family status or income bracket, and none is defined by a protected trait. That is a compliance decision and a performance one.
They have just arrived in the valley and need a bank on day one. This is the highest-intent group, and nothing about it touches a protected trait.
They have owned the same home for years and are likely to hold real deposits and to consolidate if given a reason.
Summerlin has a high share of self-employed and professional households. Business banking is where a credit union competes hardest.
They are actively unhappy with their current bank. The conquesting in the next section is built to reach them, and open eligibility removes their main reason not to switch.
Households across the eleven ZIPs, 354,041 adults. Eligibility is effectively open: Sunward arranges free American Consumer Council membership as a route anyone can take. The constraint is not who may join, it is that people assume they cannot.
| Programmatic | 60–75% |
| Streaming TV | 50–65% |
| Meta list | 45–60% |
| Cable | 40–55% |
| Streaming audio | 35–50% |
Existing members (including anyone who moved from New Mexico), employees and board members, people not eligible to join, opt-outs, and records with address or deceased flags. The list is refreshed monthly and sent to every agency on the same day.
Every file moves hashed, so we never hold a readable name or address.
Winning Competitor Searches
The rules limit who a banking ad can target, not what people search. Google blocks targeting by ZIP, age or income but places no restriction on keywords, so someone who types a competitor's name states their intent directly. Search is therefore where Sunward can compete hardest.
Sunward is a new name in this market, which makes it cheap for an incumbent to buy. Brand terms carry the lowest CPC and the highest conversion rate in the account, and losing them to a competitor is the easiest mistake in the plan to avoid.
Unbranded searches such as “credit union near me” and “checking account Las Vegas” reach people shopping for a bank before they have chosen one.
Every new member leaves someone else. We bid on the names of the institutions they are leaving, run those ads on a radius around the branch, and push hardest in the weeks around opening, when there is somewhere real to switch to.
$12,000 on defense and $48,000 on offense make up the full $60,000 search budget. The ad groups below break the offense into category terms and competitor names.
| Ad group | Stance | Keywords | Budget | Share |
|---|---|---|---|---|
| Brand Defense | DEFENSE | Sunward, Sunward Federal Credit Union, Sunward Las Vegas, Sunward Summerlin | $12,000 | 20% |
| Category Non-Brand | OFFENSE | credit union near me, checking account Las Vegas, credit union Summerlin, open a bank account | $18,000 | 30% |
| Credit Union Conquest | OFFENSE | One Nevada, Clark County CU, Silver State Schools, WestStar, America First, Greater Nevada | $18,000 | 30% |
| National Bank Conquest | OFFENSE | Wells Fargo, Chase, Bank of America, US Bank, Nevada State Bank | $12,000 | 20% |
| Total paid search | $60,000 | 100% |
Buying a competitor's name as a keyword is legal, but using it in an ad is not. Competitor trademarks never appear in our ad copy or on the landing page, and every ad talks about Sunward, not them.
The same consumer finance rule applies to these campaigns, so they cannot use the ZIP list. The section 03 tiers set bid weight, not targeting.
Spend runs $4,000 in phase one and $17,000 in phase three. Asking someone to switch works best when there is a door they can walk into this week.
Allocating the $500,000
We buy no broadcast television or radio: the footprint is 18% of Clark County, so broadcast would waste four of every five impressions.
| Channel | Role | ZIP targeting | Budget | % |
|---|---|---|---|---|
| OOH bulletins & posters | Makes a new name look established. | YES | $90,000 | 18.0% |
| Programmatic display & video | Carries everyday reach across all eleven ZIPs. | YES | $85,000 | 17.0% |
| CTV & streaming TV | Reaches cord-cutters at home, by household. | YES | $75,000 | 15.0% |
| Paid search | Catches intent and takes share from competitors. | NO | $60,000 | 12.0% |
| Paid social | Delivers broad reach and the cheapest frequency we can buy. | NO | $50,000 | 10.0% |
| Streaming audio & podcasts | Reaches commuters and at-home listeners cheaply. | YES | $35,000 | 7.0% |
| Digital outdoor | Places screens near the site to turn awareness into visits. | YES | $35,000 | 7.0% |
| Cinema | Holds a captive audience on screens inside the footprint. | YES | $30,000 | 6.0% |
| Zoned cable | Reaches local news viewers in the west valley only. | YES | $25,000 | 5.0% |
| Print & community sponsorship | Builds credibility with established local audiences. | YES | $15,000 | 3.0% |
| Total | $500,000 | 100.0% |
Channel flowchart
Every campaign line item, flight and monthly commitment. ZIP means the line can target the eleven ZIPs directly; RADIUS means platform rules force a radius instead.
| Platform & campaign | Details | Strategy | Geo | Flight | Total | Jun | Jul | Aug | Sep | Oct | Nov | Dec |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| PAID SOCIAL | ||||||||||||
| Meta - Get known 15-mile minimum radius, no ZIP targeting. Customer-list audiences permitted under certification. | Paid social | Awareness - Reach/Frequency/CPM | RADIUS | 6/1/2027 8/31/2027 | $18,000 | $6,000 | $6,000 | $6,000 | – | – | – | – |
| Meta - Get considered | Paid social | Consideration - Clicks/CTR/CPC | RADIUS | 9/1/2027 10/31/2027 | $15,000 | – | – | – | $7,500 | $7,500 | – | – |
| Meta - Open the doors | Paid social | Conversion - Appointments/Accounts/CPA | RADIUS | 11/1/2027 12/31/2027 | $17,000 | – | – | – | – | – | $8,500 | $8,500 |
| PAID SOCIAL subtotal | $50,000 | $6,000 | $6,000 | $6,000 | $7,500 | $7,500 | $8,500 | $8,500 | ||||
| PAID SEARCH | ||||||||||||
| Google Search - Brand Defense Protects Sunward brand terms so competitors cannot buy the name cheaply. Lowest CPC and highest conversion rate in the account. | Defense | Defense - Clicks/CPC/Conversion rate | RADIUS | 6/1/2027 12/31/2027 | $12,000 | $1,000 | $1,000 | $1,000 | $1,500 | $1,500 | $3,000 | $3,000 |
| Google Search - Category Non-Brand “credit union near me”, “checking account Las Vegas”, “credit union Summerlin”. Captures unbranded demand. | Offense | Offense - Clicks/CTR/CPC | RADIUS | 6/1/2027 12/31/2027 | $18,000 | $1,667 | $1,667 | $1,666 | $3,000 | $3,000 | $3,500 | $3,500 |
| Google Search - Credit Union Conquest One Nevada, Clark County CU, Silver State Schools, WestStar, America First, Greater Nevada. | Offense | Offense - Clicks/CPA/Impression share | RADIUS | 6/1/2027 12/31/2027 | $18,000 | $1,000 | $1,000 | $1,000 | $3,000 | $3,000 | $4,500 | $4,500 |
| Google Search - National Bank Conquest Wells Fargo, Chase, Bank of America, US Bank, Nevada State Bank. Switchers leaving a national for a local branch. | Offense | Offense - Clicks/CPA/Impression share | RADIUS | 6/1/2027 12/31/2027 | $12,000 | $334 | $333 | $333 | $1,500 | $1,500 | $4,000 | $4,000 |
| PAID SEARCH subtotal | $60,000 | $4,001 | $4,000 | $3,999 | $9,000 | $9,000 | $15,000 | $15,000 | ||||
| VIDEO | ||||||||||||
| MNTN - Get known Household addressable across the eleven ZIPs. Reports verified site visitation, so CTV is measured on people who reached the site, not impressions alone. | CTV / OTT | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $20,000 | $6,667 | $6,667 | $6,666 | – | – | – | – |
| MNTN - Get considered | CTV / OTT | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $13,000 | – | – | – | $6,500 | $6,500 | – | – |
| MNTN - Open the doors | CTV / OTT | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $11,000 | – | – | – | – | – | $5,500 | $5,500 |
| YouTube - Get known Geo-targeted to the ZIP list. | Online video | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $14,000 | $4,667 | $4,667 | $4,666 | – | – | – | – |
| YouTube - Get considered | Online video | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $9,000 | – | – | – | $4,500 | $4,500 | – | – |
| YouTube - Open the doors | Online video | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $8,000 | – | – | – | – | – | $4,000 | $4,000 |
| VIDEO subtotal | $75,000 | $11,334 | $11,334 | $11,332 | $11,000 | $11,000 | $9,500 | $9,500 | ||||
| PROGRAMMATIC | ||||||||||||
| StackAdapt - Get known Full-service DSP. ZIP and household addressable across the eleven ZIPs. | Display & online video | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $32,000 | $10,667 | $10,667 | $10,666 | – | – | – | – |
| StackAdapt - Get considered | Display & online video | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $26,000 | – | – | – | $13,000 | $13,000 | – | – |
| StackAdapt - Open the doors | Display & online video | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $27,000 | – | – | – | – | – | $13,500 | $13,500 |
| PROGRAMMATIC subtotal | $85,000 | $10,667 | $10,667 | $10,666 | $13,000 | $13,000 | $13,500 | $13,500 | ||||
| STREAMING AUDIO | ||||||||||||
| Spotify - Get known ZIP-targeted. | Streaming audio | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $10,000 | $3,334 | $3,333 | $3,333 | – | – | – | – |
| Spotify - Get considered | Streaming audio | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $6,000 | – | – | – | $3,000 | $3,000 | – | – |
| Spotify - Open the doors | Streaming audio | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $5,000 | – | – | – | – | – | $2,500 | $2,500 |
| StackAdapt - Podcast - Get known Programmatic podcast through the same DSP, so frequency is shared with display. | Podcast | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $6,000 | $2,000 | $2,000 | $2,000 | – | – | – | – |
| StackAdapt - Podcast - Get considered | Podcast | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $4,000 | – | – | – | $2,000 | $2,000 | – | – |
| StackAdapt - Podcast - Open the doors | Podcast | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $4,000 | – | – | – | – | – | $2,000 | $2,000 |
| STREAMING AUDIO subtotal | $35,000 | $5,334 | $5,333 | $5,333 | $5,000 | $5,000 | $4,500 | $4,500 | ||||
| DIGITAL OUT OF HOME | ||||||||||||
| StackAdapt - DOOH - Get known Screens in the trade area, weighted to the branch as opening nears. Bought in the same seat as display. | Programmatic DOOH | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $8,000 | $2,667 | $2,667 | $2,666 | – | – | – | – |
| StackAdapt - DOOH - Get considered | Programmatic DOOH | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $10,000 | – | – | – | $5,000 | $5,000 | – | – |
| StackAdapt - DOOH - Open the doors | Programmatic DOOH | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $17,000 | – | – | – | – | – | $8,500 | $8,500 |
| DIGITAL OUT OF HOME subtotal | $35,000 | $2,667 | $2,667 | $2,666 | $5,000 | $5,000 | $8,500 | $8,500 | ||||
| Total Digital Spend | $340,000 | $40,003 | $40,001 | $39,996 | $50,500 | $50,500 | $59,500 | $59,500 | ||||
| Partners · Traditional | ||||||||||||
| OOH | ||||||||||||
| Lamar - Get known Summerlin Parkway, 215 Beltway, Charleston. | Bulletins | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $20,000 | $6,667 | $6,667 | $6,666 | – | – | – | – |
| Lamar - Get considered | Bulletins | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $16,000 | – | – | – | $8,000 | $8,000 | – | – |
| Lamar - Open the doors | Bulletins | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $17,000 | – | – | – | – | – | $8,500 | $8,500 |
| Outfront Media - Get known Rainbow, Sahara. Repoints to wayfinding at opening. | Bulletins & posters | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $13,000 | $4,334 | $4,333 | $4,333 | – | – | – | – |
| Outfront Media - Get considered | Bulletins & posters | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $11,000 | – | – | – | $5,500 | $5,500 | – | – |
| Outfront Media - Open the doors | Bulletins & posters | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $13,000 | – | – | – | – | – | $6,500 | $6,500 |
| OOH subtotal | $90,000 | $11,001 | $11,000 | $10,999 | $13,500 | $13,500 | $15,000 | $15,000 | ||||
| CINEMA | ||||||||||||
| NCM - Summerlin theaters - Get known Red Rock and Downtown Summerlin screens only. | Cinema | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $12,000 | $4,000 | $4,000 | $4,000 | – | – | – | – |
| NCM - Summerlin theaters - Get considered | Cinema | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $8,000 | – | – | – | $4,000 | $4,000 | – | – |
| NCM - Summerlin theaters - Open the doors | Cinema | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $10,000 | – | – | – | – | – | $5,000 | $5,000 |
| CINEMA subtotal | $30,000 | $4,000 | $4,000 | $4,000 | $4,000 | $4,000 | $5,000 | $5,000 | ||||
| CABLE | ||||||||||||
| Cox Media Las Vegas - Get known West valley zones only. | Zoned cable | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $5,000 | $1,667 | $1,667 | $1,666 | – | – | – | – |
| Cox Media Las Vegas - Get considered | Zoned cable | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $6,000 | – | – | – | $3,000 | $3,000 | – | – |
| Cox Media Las Vegas - Open the doors | Zoned cable | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $14,000 | – | – | – | – | – | $7,000 | $7,000 |
| CABLE subtotal | $25,000 | $1,667 | $1,667 | $1,666 | $3,000 | $3,000 | $7,000 | $7,000 | ||||
| PRINT & SPONSORSHIP | ||||||||||||
| Local print & sponsorship - TBD - Get known Community partnership inventory. Partners to be confirmed. | Print / sponsorship | Awareness - Reach/Frequency/CPM | ZIP | 6/1/2027 8/31/2027 | $5,000 | $1,667 | $1,667 | $1,666 | – | – | – | – |
| Local print & sponsorship - TBD - Get considered | Print / sponsorship | Consideration - Clicks/CTR/CPC | ZIP | 9/1/2027 10/31/2027 | $3,000 | – | – | – | $1,500 | $1,500 | – | – |
| Local print & sponsorship - TBD - Open the doors | Print / sponsorship | Conversion - Appointments/Accounts/CPA | ZIP | 11/1/2027 12/31/2027 | $7,000 | – | – | – | – | – | $3,500 | $3,500 |
| PRINT & SPONSORSHIP subtotal | $15,000 | $1,667 | $1,667 | $1,666 | $1,500 | $1,500 | $3,500 | $3,500 | ||||
| Total Traditional Spend | $160,000 | $18,335 | $18,334 | $18,331 | $22,000 | $22,000 | $30,500 | $30,500 | ||||
| Total Paid Advertising | $500,000 | $58,338 | $58,335 | $58,327 | $72,500 | $72,500 | $90,000 | $90,000 | ||||
Measuring Member Growth
With no Nevada members yet, there is no history to match back to. We will say which numbers are measured and which are modeled, every month. Two partners let us measure more than most: MNTN for verified site visitation on CTV, and Azira for device-level visits to the branch itself.
| Phase | KPIs |
|---|---|
| 1 · Get known | Searches for Sunward from inside the eleven ZIPs, plus reach and frequency. |
| 2 · Get considered | Appointments booked, applications started, and impression share on conquest terms. |
| 3 · Open the doors | Accounts funded, deposits and loans, and visits to the branch. |
Searches for Sunward from inside the eleven ZIPs cost nothing to track, run continuously, and move when awareness moves, which makes them the honest early signal.
Billboards and cinema cannot be switched off by ZIP, so a clean hold-out is not possible. We compare against similar west-valley ZIPs instead and say so.
Azira matches mobile device IDs against the branch as a point of interest, so “did anyone come in” becomes a measured number rather than a model. MNTN reports verified site visitation on the CTV buy, which gives the same treatment to the largest video line.
State law bars geofencing within 1,750 feet of a health facility. The rule applies to the Azira geofence and to digital outdoor, so we screen both before launch and file the attestation.
Adjusting at Branch Opening
| Before | After | |
|---|---|---|
| Geography | All eleven ZIPs | A tight radius around the branch, ZIPs behind it |
| Channels | Reach: streaming TV, audio, cinema | Proximity and response: digital outdoor, search, addressable |
| Conquesting | $4,000 in phase one, testing which competitors convert | $17,000 in phase three, pushed on switch-now messaging |
| Outdoor | Presence and name recognition | Directions to the door |
| Message | Who Sunward is | Come in, book a time, open an account |
| KPIs | Branded search and reach | Accounts, appointments, branch visits |
| Frequency | 52% monthly reach at 10× | 80% monthly reach at 10×, burst at opening |
Flagging Risks Before Launch
Each item below rests on sources that disagree or a fact Sunward has not yet confirmed, and each is resolved before any money is committed.
Sun City Summerlin, a Del Webb community of 7,779 homes and more than 12,500 residents, sits inside 89134 and generally requires at least one resident per home to be 55 or older. The ZIP also includes other neighborhoods and commercial areas, so it is not wholly age-restricted. Community figures come from real-estate sources and are confirmed against Census data before launch.
89134 stays in the plan because it sits in the trade area, never because of residents' age. Age is protected under fair lending law, and using a ZIP as a stand-in for it remains prohibited, so the written business rationale is what makes the buy defensible.
Google permits Customer Match for consumer-finance ads in principle: its outright ban covers sensitive-interest categories, not consumer finance. What it prohibits is a list selected by age, gender, parental or marital status, or ZIP, and deleting those columns afterward does not cure the list. The file must also be collected first-party, through Sunward\'s own website, app or customer contact with the required consent, so a compiled prospect list cannot be used.
Customer Match is permitted in principle; Sunward's specific file and use case remain unconfirmed. We get written confirmation from Google on that configuration before relying on it. That is our safeguard, not a Google requirement.
Documenting the Regulations
These are the platform restrictions, the governing law, and the rules specific to credit unions and to Nevada, current as of September 2026. Every targeting decision in this plan rests on them.
A · Google Ads policy
Policy name: Access to opportunities, covering consumer finance. In force since February 2024. Scope is credit cards, loans, banking and debt management, so it applies to Sunward's deposit and membership advertising, not only to lending.
| Restriction | Policy | Effect on this plan |
|---|---|---|
| ZIP codes | ZIP targeting is prohibited. Country, state, city and radius targeting are allowed, with a 1 km minimum radius. | Search runs on a radius around the branch. The eleven ZIPs set bid weight, not targeting. |
| Demographics | No targeting or exclusion by age, gender or parental status. All demographic options must be set to Enable, and demographic bid adjustments removed or set to 0%. | We check account settings as well as campaign settings at build, because a leftover bid adjustment is a policy breach. |
| Marital status & life events | No targeting on marital status, including single, married or in a relationship, and no marriage-related life events such as getting married soon. | This rules out a common banking audience tactic. Our four segments avoid it by design. |
| Audience lists | Customer Match and remarketing lists cannot use demographic, marital status, parental status or ZIP code signals to build the list. | A list selected by ZIP cannot be used. Sunward's file has to be built on non-geographic criteria, with geography coming from campaign radius. It must also be first-party data Sunward collected itself, with the required disclosures and consent. |
| Age eligibility | Personalized advertising of any kind cannot target users under 18. | No effect. Nothing in this plan targets minors. |
| Responsibility | Google requires the advertiser to audit lists and settings for restricted signals before launch. | We make this a pre-launch checklist item with written sign-off. |
B · Meta policy
Category name: Financial Products and Services. Replaced the previous Credit category on 14 January 2025 and is mandatory for US advertisers and anyone targeting the US.
No ZIP targeting. Location targeting has a 15-mile minimum radius in the US.
Age locked to 18–65+ with no gender exclusions permitted.
No lookalike audiences and no Advantage audience expansion.
Customer list audiences are permitted, uploaded directly to the account under certification.
Lists cannot be shared across ad accounts outside the same business portfolio and email domain.
The account must be certified before campaigns in this category can publish.
C · ZIP targeting by channel
The restrictions above apply only to Google and Meta, so the other 78% of the plan still reaches the eleven ZIP codes. The reason differs by channel: there are two ways to be geographically exact, and only one of them is regulated.
The inventory itself is geographic: a billboard face, a screen, a cinema auditorium, a cable zone, a publication's catchment. No personal data decides who sees the ad, so the personalized advertising rules have nothing to attach to. This money is insulated by construction, not by permission.
These platforms do use personal and household data, and they can currently target the eleven ZIP codes because they have not adopted the restrictions Google and Meta did. That is a difference in policy, not in law. If the same pressure reaches them, this is the money that moves.
| Channel | Targeting method | Budget | Exposure |
|---|---|---|---|
| Place-based inventory, structurally insulated | |||
| OOH bulletins & posters Lamar, Outfront |
A face at a fixed coordinate. You are buying the location, and the audience is whoever drives past it. | $90,000 | STRUCTURAL |
| Programmatic DOOH StackAdapt |
Screens at fixed addresses, bought by location and daypart. Programmatic refers to how the slot is purchased, not to targeting a person. | $35,000 | STRUCTURAL |
| Cinema NCM Summerlin theaters |
Bought auditorium by auditorium. Precision comes from which theaters sit inside the trade area. | $30,000 | STRUCTURAL |
| Zoned cable Cox Media Las Vegas |
Cox inserts advertising at the headend into defined geographic zones. The precision is in the cable plant, not in an audience segment. | $25,000 | STRUCTURAL |
| Print & sponsorship Local, to be confirmed |
Circulation and catchment area. The publication's own footprint does the targeting. | $15,000 | STRUCTURAL |
| Subtotal | $195,000 | ||
| Household data, currently unrestricted | |||
| Programmatic display & video StackAdapt |
Postal code is a standard field in the bid request, so the platform can filter on it directly. Household addressability comes from IP and an identity graph. | $85,000 | POLICY |
| CTV & streaming TV MNTN |
A television sits at a fixed address, so resolving an IP to a household is unusually reliable here. Targeting is by household first, then rolled up to the ZIP list. | $75,000 | POLICY |
| Streaming audio & podcasts Spotify, StackAdapt |
Both platforms offer postal-code targeting as standard. Podcast delivery is closer to market level, so it is weighted rather than precisely aimed. | $35,000 | POLICY |
| Subtotal | $195,000 | ||
| Total able to target the ZIP list | $390,000 | ||
We confirm each partner's policy at build as part of pre-flight, rather than assuming it from category, because a platform can add a financial services restriction between plan approval and launch.
None of this is a legal distinction: every channel here is lawful. Google and Meta restricted themselves under civil rights litigation and settlement pressure that has not yet reached the rest of the market. If it does, the place-based half of the plan is unaffected, because no personal data enters the transaction. The addressable half is where any future restriction lands first, and it is the number to watch.
D · Federal law
Platform policy is not law. These statutes and regulations govern financial advertising whether or not a platform enforces them.
| Rule | Scope | Current position |
|---|---|---|
| ECOA / Regulation B | Discrimination in credit, including discouraging applicants through advertising. | Amended April 2026, effective 21 July 2026. The effects test was removed and disparate impact is no longer recognized under ECOA. Discouragement now turns on statements of intent. Intentional and proxy discrimination remain prohibited, which is why we document the trade area on business grounds. |
| Fair Housing Act | Advertising for mortgage and home lending. | HUD is rescinding its disparate-impact regulations, but the statutory theory survives in the courts and the Act carries a private right of action. This applies only if Sunward advertises mortgage or home equity in Nevada. |
| FCRA §604(c) | Use of credit bureau data to select an advertising audience. | Prescreened lists make the advertisement a firm offer of credit. That triggers the firm-offer requirement, the prescreen opt-out notice, and five-year retention of the selection criteria. We keep bureau data out of awareness targeting entirely. |
| GLBA / Regulation P | Sharing member data with an agency or platform. | Permitted under the service provider and joint marketing exception, with a written contract in place. Files move hashed and the agency holds no readable member data. |
E · Credit union law
NCUA examines here, not the CFPB. It enforces ECOA and Regulation B in federal credit unions, and HMDA and the Fair Housing Act in all federally insured ones. It has named redlining, marketing and pricing among its fair lending examination priorities.
Federal credit unions are exempt from CRA, so there is no assessment-area obligation of the kind that shapes bank marketing footprints. Several states impose CRA-like requirements on state-chartered credit unions, and Nevada's position needs confirming.
A credit union can only advertise membership to people eligible to join. Sunward arranges free American Consumer Council membership, a route open to anyone, so eligibility is effectively open. What limits the audience is that people assume they cannot join. The Nevada field of membership still needs confirming against the charter.
F · Nevada law
In force since 31 March 2024, the law prohibits geofencing within 1,750 feet of a health care facility for data collection or targeted advertising. The Attorney General enforces it as a deceptive trade practice, and there is no private right of action. It applies directly to our point-of-interest measurement and to digital out-of-home, so we screen both before launch.
Nevada has an opt-out regime for the sale of covered information, not a comprehensive privacy act. GLBA-regulated institutions are exempt from parts of it, but any third-party data vendor in the plan should be able to document its position.
G · Rule changes since 2024
Three material changes landed in roughly two years. Google restricted ZIP targeting for consumer finance in February 2024. Meta replaced its Credit category in January 2025. Regulation B was rewritten in April 2026. Each would have invalidated part of a plan written the month before it.
The direction of travel is consistently toward less targeting, not more. Section C splits the exposure: the $195,000 in place-based inventory is insulated by construction, and the $195,000 running on household data is what a policy change could take away. We monitor that figure across every partner in the plan, not only the two that already restrict us.