Marketing has created a list of services that the bank offers (checking, savings, loans, investments, etc.) in a creative design. The window cling will only be visible inside the bank. The bank name, member FDIC, Equal Housing Lender and Not, Not, May are not included on the window cling.
Can we omit these disclosures since it is in the lobby and the list is generic?
If we are listing OREO property for sale in the newspaper, must we include the FDIC or Equal Housing Lender information?
On our banking website do we need both the equal housing lender logo AND disclosure? I read that we do but can find one banking website that actually does.
I once read something that stated the Equal Housing Lender logo (EHL) should be displayed anywhere a home loan application is received. Should a national bank have the EHL logo displayed on each loan officer/customer service desk where home loan applications are received or is the lobby poster sufficient?
Our bank compliance officer left last fall for another job. I am in charge of our electronic sign and need to find out where there is a clear/concise source of information that guides us in what we have to disclose on the sign for interest rates, terms, etc.
We’d like to advertise a promotion that states: "Business and Real Estate Loans from 4.5%. Floating rate for Highest Quality Credits." Will there be any compliance issues, such as trigger terms, etc?
One of our mortgage lenders would like to place an ad in the classified portion of the local newspaper. The ad reads: Have you filed bankruptcy or had your home foreclosed on in the past two years? Call [name] to get your credit checked. You may be eligible to purchase a home. Numerous programs available to be a homeowner again. Then she lists her name and cell phone. The bank is not mentioned. Does it need to be? Would this ad be considered compliant? What would make it compliant? Is this a bad idea?
Our commercial lending area is using the website to advertise their products. As commercial lenders, they maintain they are not held to the same requirements as our home mortgage lenders. One example is the Equal Housing Lender logo. It isn't on the web page and we believe it should be in order to be in compliance. Who is right?
We are partnering with a realtor with a sign promotion of a development. We will post Financing Available at First National Bank [Name of Bank Withheld]. What are the requirements for this sign - such as Member FDIC - Equal Housing etc?
With budgets tightening we want to combine some of our advertisements to get the most for our advertising dollars. We have always advertised loans separate from deposits, as one example, and generally advertised one specific product at a time. As we combine ads, what precautions do we need to take?