Are there any rules/considerations to think of if a loan officer pays for their own advertising?

You mean besides the fact that it Is going to be hard to control content and distribution and how that impacts your overall outreach efforts for CRA and fair lending purposes? Bad idea all around. Do your deposit operations or commercial loan officer pay for their own advertising? If the company wants to advertise, the company pays.

Individual lenders are not exempt from the advertising rules of Regulation Z. See Section 1026.2(a)(2), OI #2. I'm with Randy--freelance self-promotion is a bad idea. Instead, you would be wise to adopt a policy that no officer or employee is permitted to post messages in public media if the messages contain the bank's name. That goes for the full range of print, electronic, and broadcast media.

Those are my thoughts, as well, and that is our current policy. We were just made aware of a lender that pays for their own, and I couldn't think of anything that would prohibit it outright. I was just asked to look into what made it okay for them to do so.

I was just asked to look into what made it okay for them to do so.

I would chalk it up to the lack of and/or poor management

"I was just asked to look into what made it okay for them to do so."

I think I would have told them to ask the LO themselves! They came up with it, so they best have a good reason as to why they thought they could skirt policy/procedure/regulation/etc...

If there's any kind of promotional message with your bank's name on it, regulators will expect you to control it and keep it compliant. Anything less will probably get a "dog ate the homework" reception. Keeping the official ads clean for your marketeers probably takes more time than you like. If you allow your sales force to roll their own, that digs deeper into a scarce resource your bank needs for other things. The cleanest & simplest way to handle this is to adjust policy (if necessary) and declare that NOBODY other than the marketing officer (or designee) can authorize the use of the bank's name in any public statements about products and services--especially electronic statements. If the sales force can work within the system, that's good...and it takes no more of your time.

This was a loan officer at another bank, and it was brought up to see if it's something we could allow at ours. I am against it, but I was asked to do some research on it. Thank you to everyone for your input.

Years ago, we were looking to move and picked-up one of those free real estate magazines that you find in some supermarkets. One of the (brand new) loan officers took out a personal ad in there. Probably the only compliance thing he got right was spelling his name correctly.

There was a strong compliance culture in the bank, and the bank listed out the violations, including the potential regulatory liability that he was putting on the bank.