I know the Member FDIC language issue has been discussed a lot on BOL. But I couldn't find much regarding officer promotion posts. So for example, John Doe was promoted to assistant vice president at XYZ Bank.

Does a post like this require the Member FDIC language? If the person was a mortgage lender, would it require the Equal Housing logo and NMLS #.

Initially, my thoughts were that Member FDIC was not required. But then I thought about the potential of needing the Equal Housing lender logo and NMLS # if the post referenced the employee's position as a lender at the bank.

I know the easy answer is to slap those things on the post and move on. However, in this case, I'm performing an audit and I'll need more than a cost analysis thought process if I indicate that this is a finding. Your help is greatly appreciated.

Do any of these HR-type announcements include any advertising? Certainly, if an announcement of a new mortgage loan officer is published, it is likely to include something like "See [insert name here] at our [branch name] office for your home loan needs." That would be an advertisement, and you would need the EHL. For some reason, banks feel the need to include an MLO's NMLS # in ads. There is no requirement to do that, but no prohibition, either.

But if it is only an announcement and not an ad, you don't need Member FDIC or the EHL.