Scrolling Electronic Signs and the Equal Housing Lender Logo
Answer by Dennis Deischer and Andy Zavoina Guru Bios
Question: On scrolling electronic signs, when you advertise loans, does the "equal housing lender" logo have to be displayed?
Answer by Dennis Deischer:
My understanding is that the type of advertising you refer to is exempt from the display of the logo.
Answer by Andy Zavoina:
I would be of the opposite opinion of Dennis. I don't recall an exemption for this but the Regs do seem pretty inclusive. And while more current opinions address electronic advertising (and stating that this is required) it was intended for the Web.
We have the outside signs that you put individual letters on and when I last looked into this, we did no home loan advertising because we didn't have a doghouse logo for it. That requirement has gone away from OCC regulated banks, but in all my readings it is still a practice that is encouraged. Short of getting a specific cite, you might talk to your regulator.
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