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#1266680 - 10/14/09 08:19 PM Equal Housing Lender logo usage
WHEDA Offline
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WHEDA
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Wisconsin
Is the Equal Housing Lender logo required on all written correspondence from a financial institution or only on correspondence relating to residential lending?

I have seen the same house outline logo but one had text reading "Equal Housing Lender" and the other reading "Equal Housing Opportunity". Which is correct?

Please regulatory reference #s when available.

Thanks.

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Lending Compliance
#1268676 - 10/18/09 06:06 PM Re: Equal Housing Lender logo usage WHEDA
David Dickinson Offline
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Central City, NE
Only if you are promoting home loans. Refer to §338.4(a) (the FDIC's version).
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#1269842 - 10/20/09 05:37 PM Re: Equal Housing Lender logo usage David Dickinson
WHEDA Offline
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Thank you, David. Do you, by any chance, have a regulatory reference for your response to my first question?

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#1270154 - 10/20/09 08:57 PM Re: Equal Housing Lender logo usage WHEDA
CompDat Offline
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USA
Any bank which directly or through third parties engages in any form of advertising of any loan for the purpose of purchasing, constructing, improving, repairing, or maintaining a dwelling or any loan secured by a dwelling shall prominently indicate in such advertisement, in a manner appropriate to the advertising medium and format utilized, that the bank makes such loans without regard to race, color, religion, national origin, sex, handicap, or familial status.

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#1270183 - 10/20/09 09:13 PM Re: Equal Housing Lender logo usage CompDat
WHEDA Offline
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Wisconsin
I'm sorry if my question wasn't clear. I am asking about stationery, late notices, escrow analysis', and other correspondence, not advertising. Thanks

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#1270651 - 10/21/09 04:33 PM Re: Equal Housing Lender logo usage WHEDA
David Dickinson Offline
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David Dickinson
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Originally Posted By: WHEDA
Thank you, David. Do you, by any chance, have a regulatory reference for your response to my first question?

The regulatory reference is in my first post.
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#1270812 - 10/21/09 06:28 PM Re: Equal Housing Lender logo usage David Dickinson
WHEDA Offline
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WHEDA
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Wisconsin
Thanks David, but FDIC §338.4(a) discusses fair housing poster requirements but my questions relates to letters, late notices, escrow analyses', etc.

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#1270842 - 10/21/09 06:48 PM Re: Equal Housing Lender logo usage WHEDA
CompDat Offline
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USA
I am fairly new to the party in the = housing lender discussions but I don't think sending an escrow notice qualifies a promotion. However, if you put it on your form you can prevent the "random wierd" criticism.

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#1272306 - 10/23/09 12:03 PM Re: Equal Housing Lender logo usage CompDat
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WHEDA
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Wisconsin
Bump to David Dickinson.

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#1272323 - 10/23/09 12:48 PM Re: Equal Housing Lender logo usage WHEDA
Dan Persfull Offline
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I'm not David, but letters, past due notice and escrow statements do not require the EH logo and legend UNLESS they contain a promotion for any of your housing loan products.

Such, if the letter says something to the effect to contact one of your branches to discuss one of your many mortgage loan products then you need the EH logo and legend because you are now promoting your mortgage loans.

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#1272329 - 10/23/09 12:55 PM Re: Equal Housing Lender logo usage Dan Persfull
Kathleen O. Blanchard Offline

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Agree with Dan and David. You only need the equal housing logo in letters and notices of any kind IF you include advertising language about residential mortgage products.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1272574 - 10/23/09 03:17 PM Re: Equal Housing Lender logo usage Kathleen O. Blanchard
David Dickinson Offline
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Central City, NE
Sorry I referenced the wrong citation. Advertising requirements are found in §338.3.
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#1272576 - 10/23/09 03:17 PM Re: Equal Housing Lender logo usage Kathleen O. Blanchard
WHEDA Offline
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WHEDA
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Wisconsin
DUH!!!! Thank you for helping me get David's message through my thick skull!

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#1281552 - 11/05/09 04:36 PM Re: Equal Housing Lender logo usage Dan Persfull
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Originally Posted By: Dan Persfull
I'm not David, but letters, past due notice and escrow statements do not require the EH logo and legend UNLESS they contain a promotion for any of your housing loan products.

Such, if the letter says something to the effect to contact one of your branches to discuss one of your many mortgage loan products then you need the EH logo and legend because you are now promoting your mortgage loans.


If operations dept. mails early disclosures to applicants with a cover letter and the letter says thank you for applying for a mortgage loan and then lists the enclosures would it be okay NOT to include the EHL and legend on the cover letter or do you think it fits your point above and is required?

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#1281577 - 11/05/09 04:47 PM Re: Equal Housing Lender logo usage Runreb
Kathleen O. Blanchard Offline

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A letter containing disclosures is not an ad just because you said thank you for applying for a mortgage.

An ad is a solicitation for business...you already have the business.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1281721 - 11/05/09 06:10 PM Re: Equal Housing Lender logo usage Kathleen O. Blanchard
Runreb Offline
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Runreb
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Thanks for your reply.

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