FDIC Proposes Burden Relief in Fair Housing Reg
The FDIC has proposed changes to its fair housing regulation that would simplify compliance and make the regulation consistent with other regulatory requirements.
The regulation would be revised to reflect recent changed adopted by HUD to its fair housing regulations and to provide alternative methods for compliance in advertising. ?338.3(a)(1) Advertising, would be revised to permit use of either the FDIC "Equal Housing Lender" logotype and language or HUD's "Equal Housing Opportunity" logotype and language. Similar options would be provided for oral advertisements, including use of "Equal Opportunity Lender." This increased choice would both facilitate compliance and enable banks to use statements that are consistent with a variety of products covered by the advertisements. The FDIC regulation does not contain any specific requirement for equal housing lender logo size.
Section 338.4 would be revised to permit state non-member banks to use either the Equal Housing Lender Poster specified in the FDIC's regulations or the Equal Housing Opportunity poster specified in HUD's regulations, 24 CFR 110.25(a). The poster must be placed in a central location where either deposits or loan applications are taken. A bank would only have to display one poster and could choose the most appropriate location.
The most significant proposed revision would make FDIC's data collection requirements consistent with those of Regulation C, Home Mortgage Disclosure. The proposed rule would require state non-member banks to comply with Regulation C's requirement to maintain a Loan Application Register ("LAR") In addition, collection of any other monitoring information would be consistent with Regulation B's ?202.13. However, the FDIC would continue to require banks to record and report reasons for denial.
Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 15, 10/96
First published on 10/01/1996