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#2253585 - 05/06/21 05:57 PM Financed by signs on construction sites?
ccman Offline
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Is there a privacy concern when the bank places a "Financed by" or "Funding by" sign on a commercial construction site?

Thanks.

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#2253592 - 05/06/21 06:20 PM Re: Financed by signs on construction sites? ccman
rlcarey Offline
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Whose privacy? Are you not getting permission from the commercial customer to post such a sign - in writing with the proper liability agreements?
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#2253602 - 05/06/21 07:16 PM Re: Financed by signs on construction sites? rlcarey
ccman Offline
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Yes, are there any other privacy concerns by placing the sign on our customer's property?

Thanks.

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#2253604 - 05/06/21 07:45 PM Re: Financed by signs on construction sites? ccman
rlcarey Offline
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Like what? You have a signed agreement to allow you to place a sign on the property. I cannot imagine how that violates the privacy of anyone.
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#2254303 - 05/24/21 08:26 PM Re: Financed by signs on construction sites? ccman
John Burnett Offline
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I think the OP's concern might involve a loan to individuals who have hired a builder to construct the dwelling. But even under those circumstances, the lender would have an agreement with the borrower(s) to erect the sign. That would qualify for an exception from Regulation P under §1016.15(a)(1).
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#2270222 - 05/09/22 09:39 PM Re: Financed by signs on construction sites? John Burnett
Ann Offline
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South Carolina
In a related matter, is Member FDIC required on this sign?

A question asking if we place these signs on construction sites is on our Deposit Audit questionnaire and I don't recall it being on there before.

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#2270226 - 05/09/22 10:08 PM Re: Financed by signs on construction sites? ccman
rlcarey Offline
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Totally depends on what your signs say.
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#2270230 - 05/09/22 10:25 PM Re: Financed by signs on construction sites? rlcarey
Ann Offline
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Financed by "Anytown Bank" with Bank logo". Includes name and phone number of commercial lender.

I'm thinking yes based on this...For purposes of this § 328.3, an advertisement promotes non-specific banking products and services if it includes the name of the insured depository institution but does not list or describe particular products or services offered by the institution. An example of such an advertisement would be, “Anytown Bank, offering a full range of banking services.”

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#2270232 - 05/09/22 10:51 PM Re: Financed by signs on construction sites? ccman
rlcarey Offline
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That is where I was going with my question - so I agree. "Financed by" is pretty non-specific.
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