What is the latest ruling for use of the Equal Housing Lender logo in print advertising? For OCC regulated banks, may we use the words Equal Opportunity Lender instead of Equal Housing Lender with our doghouse logo? What about using the words Equal Opportunity Housing?
Does a Tax Service fee have to be included on the TIL disclosure? In a highly reputable banking compliance publication that shall remain unnamed, I recently read an article entitled "Grossing Up Public Assistance Income". In this article it stated "Under ECOA, while making loan approval decisions, banks must not discriminate against applicants who receive public assistance income. Generally this income is exempt from federal income taxation. If the income is exempt from taxation, then before making a loan approval decision, this exempt income needs to be grossedup to a pretax, taxable incomeequivalent amount." The article goes on to say that a "client bank" was written up for not doing this and the examiners also said that this also needed to be spelled out in the bank's loan policies and procedures manual. I've read every word in my Federal Reserve Manual under Regulation B, to include the commentary, and can find no reference to this. In the past, we have always considered this to be a "gross" income since it was not t axed. I have a HMDA related loan that has an sole income source of Social Security Benefits and need to know what my "gross" income figure is. I would appreciate any assistance that you could give me in light of this new information. Thank you in advance for your help.