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#2173203 - 04/12/18 03:54 PM
EHL logo required
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Gold Star
Joined: Jan 2012
Posts: 303
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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.
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#2173205 - 04/12/18 04:00 PM
Re: EHL logo required
Everest
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Power Poster
Joined: Sep 2010
Posts: 2,661
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Who is your regulator?
_________________________
Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2173207 - 04/12/18 04:07 PM
Re: EHL logo required
Everest
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10K Club
Joined: Oct 2000
Posts: 10,180
Toano, VA
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You could, of course, slap it on everything and skip the decision. There's no "wrong" place to put this one.
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...gone fishing.
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#2173218 - 04/12/18 04:33 PM
Re: EHL logo required
Everest
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Gold Star
Joined: Jan 2012
Posts: 303
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Our regulator is the OCC.
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#2173224 - 04/12/18 04:48 PM
Re: EHL logo required
Everest
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Power Poster
Joined: Sep 2010
Posts: 2,661
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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.
_________________________
Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2173244 - 04/12/18 06:01 PM
Re: EHL logo required
Everest
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Gold Star
Joined: Jan 2012
Posts: 303
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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.
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#2174498 - 04/20/18 05:28 PM
Re: EHL logo required
Everest
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Power Poster
Joined: Sep 2010
Posts: 2,661
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Thanks for the citations and reference, David.
_________________________
Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2175012 - 04/24/18 10:34 PM
Re: EHL logo required
Everest
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Diamond Poster
Joined: Nov 2004
Posts: 2,309
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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_14I would include the EHL legend and logotype.
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#2176268 - 05/02/18 12:21 PM
Re: EHL logo required
Everest
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100 Club
Joined: Aug 2006
Posts: 144
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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!
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#2177153 - 05/08/18 02:51 PM
Re: EHL logo required
Everest
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100 Club
Joined: Aug 2006
Posts: 144
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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?
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