Clarification on the EHL Doghouse Logo
by Mary Beth Guard, BOL Guru
Question: On print advertising, are we allowed to use just the text "Equal Housing Lender" or do we always need the complete "doghouse" logo? Is there any instance, besides oral advertising, where it is acceptable to use just the written words?
I have looked up Section 338.3 of the FDIC rules but it conflicts with information a co-worker gave to me re: July 14, 1997 letter from Carmen J Sullivan with the subject of FDIC Finalizes Fair Housing Regulation (FIL-66-97). From the letter it looks like an organization may use the "Equal Housing Lender" poster, logotype or legend. This letter gives us more options than Section 338.3.
Answer: The cover letter from Carmen Sullivan that appeared with the FIL wasn't quite as clear as it should have been. In attempting to briefly describe the changes to 338.3 described in FIL-67-97, the letter can give the wrong impression. It is the regulation itself, however, Section 338.3, which controls. In print advertising, you are required to use the doghouse. You simply have doghouse options -- Equal Housing Lender or Equal Housing Opportunity. It is only in oral advertisements that the simple words "Equal Housing Lender" or "Equal Opportunity Lender" may be used.
The original version appeared in the October 2002 edition of the Oklahoma Bankers Association Compliance Informer.
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