Is the EHL logo when you are not advertising for a specific home loan product (ex. HELOC, 30 Yr Mortgage Loan)?
We are going to be using some advertising that just uses comments such as "When You Buy or Refinance a Home" and "When buying, selling or refinancing a home" and are wondering if these comments would require the the EHL to be on them.

Thanks.

Who is your regulator?

You could, of course, slap it on everything and skip the decision. There's no "wrong" place to put this one.

Our regulator is the OCC.

I agree with Richard that the easiest approach is to just include it. I was going to find the actual citation, but can't find it at the moment. Maybe another BOL poster will have it handy.

We generally do include it on most, however this would be a one off situation where if it did not need to be included it would be beneficial for generating these documents.

Adam: The reason you can't find it is Part 109 was eliminated 5/1/1996 by HUD and not replaced. The OCC dropped the requirement at that time. OCC regulated banks must still display the EHL Poster, but they don't have to have the logo in print advertisements.

If a non-OCC institution promotes home loans, here's some notes and citations for them:
Federal Reserve regulated institutions must use the term “Equal Housing Lender”. FDIC and NCUA regulated institutions may use either “Equal Housing Lender” or “Equal Housing Opportunity”. Savings institutions (regardless of regulator) must use “Equal Housing Lender”. [12 CFR 338 (FDIC)/24 CFR 110 (OCC)/Section 6-1500 (FRB)/12 CFR 701.31 (NCUA) Savings Associations: 12 CFR 128 (OCC regulated)/12 CFR 390 (FDIC regulated)].

In other words, just saying "Come see us for your home loan needs" would trigger the logo.

Thanks for the citations and reference, David.

If you are a federal savings association regulated by the OCC, see 12 CFR 128.4. https://www.ecfr.gov/cgi-bin/text-idx?SI...5#se12.1.128_14

I would include the EHL legend and logotype.

If the ad simply says "Refer a friend for an account or to apply for a loan. Thank you for banking with us!" Is the EHL disclosure required? We are regulated by FDIC. Having said that, would we need "Memeber FIDC" in the ad(?)...bank name is not mentioned because this was only displayed at a reception the bank hosted for its customers. Thanks!

You don't mention home loans, so the EHL logo is not triggered. Technically, signs in the banking office do not need "Member FDIC".

Thanks, David, for the guidance. The customer reception was hosted at a local venue not within the bank itself. Would this mean that the "Member FDIC" should have been in the ad?

Yes.

Are there various EHL logo options besides the house above the "Equal Housing Lender" language that a FRB regulated bank can utilize? Can someone please provide a citation for this? I am unable to locate this information using the "Section 6-1500 (FRB)" citation David provided above.

Thank you.

Any feedback on my post above, please? Thanks in advance.

You are most likely looking for the original Board Order.

Board Order, 54 Fed. Reg. 11567 (March 21, 1989)

https://www.govinfo.gov/content/pkg/FR-1989-03-21/pdf/FR-1989-03-21.pdf

Are there various EHL logo options besides the house above the "Equal Housing Lender" language that a FRB regulated bank can utilize?
No. As I mentioned in my previous post, Federal Reserve regulated institutions must use the term “Equal Housing Lender”. The logo is exactly what it is: the house above the words. No variations or other options allowed.

Thank you both very much; incredibly helpful as always.

I didn't want to assume that "term" and "logo" were synonymous, so I appreciate the clarification.