Does a mortgage advertisement need to display the EHL logo, or is written text stating "Equal Housing Lender," acceptable? I realize the logo has the text underneath the little house, but marketing is trying to get an advertisement through using only the text. Before I send it back and ask for the logo, I want to see if others agree.

Thoughts, please?

§ 338.3 Nondiscriminatory advertising.

(a) 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.

(1) With respect to written and visual advertisements, this requirement may be satisfied by including in the advertisement a copy of the logotype with the Equal Housing Lender legend contained in the Equal Housing Lender poster prescribed in § 338.4(b) of the FDIC's regulations or a copy of the logotype with the Equal Housing Opportunity legend contained in the Equal Housing Opportunity poster prescribed in § 110.25(a) of the United States Department of Housing and Urban Development's regulations (24 CFR 110.25(a)).

(2) With respect to oral advertisements, this requirement may be satisfied by a statement, in the spoken text of the advertisement, that the bank is an " Equal Housing Lender" or an "Equal Opportunity Lender."

To leapfrog onto this, what about text only mediums that do not allow the use of pictures (i.e. the logotype)? Doe the phrase " in a manner appropriate to the advertising medium and format utilized" give enough wiggle room to use the written statement rather than the logotype? I'm looking at you twitter.

manner appropriate to the advertising medium and format utilized

Hence you have paragraphs 1 and 2, which tells you what is appropriate.

This still leaves a bit of a pickle. Yes, paragraphs 1 and 2 tell you what is appropriate, but assumes that the written advertisement will support the use of the logotype. If it is a written medium, but cannot have the logotype included then what? I'm looking at you too google.

Following up on this topic.
We are FDIC regulated and being asked to consider a digital text ad for home loans. The medium is unable to support the logo. The way I read it is that a digital text ad is visual, thus logo requirement of paragraph one apply.

Interested in what others think...............

I agree the logo (house and words) are both required because this is a visual ad. There is no exemption for digital text ads. This is another regulatory issue that hasn't kept up with technology (or you could say the technology needs to conform to the regulation).

Thanks David - appreciate your help

If the add in question has a "one click" link to important disclosures, is that meeting the requirement of the logo for a visual add ?

There Is no regulatory "one click" rule for the EHL logo.

Thank you!!