The ad that I'm reviewing is promoting a loan assistance program in which the bank will waive fees, extend maturities and allow flexible payment options for borrowers that have encountered financial issues through the COVID crisis. The ad in question does not have the EHL.

I know the logo is required for advertising any loan for the purpose of purchasing, constructing, improving, repairing, or maintaining a dwelling or any loan secured by a dwelling. However, I'm not sure the assistance program is a "loan" for the purpose of EHL requirements. The program is for loans that have already been underwritten.

Any thoughts? I know the easy thing would have been to slap the logo on there and be done with it. I basically see the assistance program like a modification agreement. And when I look up COVID modifications on the webs, most banks are going and disclosing the EHL logo.

Your help is greatly apperciated.

So you think offering a loan modification is not a loan/lending product??

The program is housing related. I don't understand the thinking that avoids including the EHL (or Member FDIC for deposit ads) for "gray area" ads. It can't be the cost, because you can waste more than the cost just discussing the issue.

I agree. The "easy thing would have been to slap the logo on there and be done with it."