Question: Do we have use both the "Equal Housing Opportunity" and the "Equal
Credit Opportunity" logos on our lending advertisements or is just one of
them sufficient? We're a state-chartered nonmember bank.
Answer: You do not need to use both. You need to use "Equal Housing Lending" or "Equal Housing Opportunity". The Equal Housing advertising requirements are covered under Section 338.3 of the FDIC rules for state-chartered nonmember banks. They come into play when a bank, directly or through third parties, engages in any form of advertising of any loan for the purpose of:
purchasing,
constructing,
improving,
repairing, or
maintaining
a dwelling or any loan secured by a dwelling.
The ads must, in a manner appropriate to the advertising medium and format utilized, indicate that the bank makes such loans without regard to race, color, religion, national origin, sex, handicap, or familial status.
Specifically, in written and visual advertisements, you can satisfy the requirement by including a copy of the Equal Housing Lender logotype OR the Equal Housing Opportunity logotype, along with the
words "Equal Housing Lender" or "Equal Housing Opportunity."
On oral advertisements, you can satisfy the requirement by including a statement, in the spoken text of the advertisement, that the bank is an " Equal Housing Lender" or an "Equal Opportunity Lender."
The original version appeared in the October 2002 edition of the Oklahoma Bankers Association Compliance Informer.
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