Skip to content
BOL Conferences Top Gun 23
Learn More - Click Here!

Thread Options
#2277004 - 10/24/22 08:44 PM Digital Picture Frame with multiple state licenses
Compliance0411 Offline
Junior Member
Joined: Jun 2022
Posts: 26
As we have just relocated to a new facility we are tasked with framing and displaying 38+ licenses for the various states in which we are licensed to lend. Someone in HR suggested utilizing a rotating digital pictures frame for the state licenses to display on a continued basis. Is this acceptable. I would not substitute this for hard copy HMDA and FHA signs but was wondering if this works for the various state licenses we need to display in our main office. This will certainly look a great deal more professional than covering a wall with mis matched frames. Looking for advice.

Thanks,

Return to Top
#2277011 - 10/24/22 09:17 PM Re: Digital Picture Frame with multiple state licenses Compliance0411
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,363
Galveston, TX
What specific licenses are you trying to display? For example, I am not aware that you are required to display a copy of any license that you may have from Texas.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2277017 - 10/24/22 10:03 PM Re: Digital Picture Frame with multiple state licenses Compliance0411
Compliance0411 Offline
Junior Member
Joined: Jun 2022
Posts: 26
We have always been told by our regulators, for the various states we do lend in, that we are to display their state license. Have we been misinformed?

Return to Top
#2277018 - 10/24/22 10:08 PM Re: Digital Picture Frame with multiple state licenses rlcarey
Compliance0411 Offline
Junior Member
Joined: Jun 2022
Posts: 26
We are not licensed in Texas

Return to Top
#2277019 - 10/24/22 10:40 PM Re: Digital Picture Frame with multiple state licenses Compliance0411
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,363
Galveston, TX
OK, you still have not told us what license you are referring too. If you have to display the license, then it would be a State law. If you are referring to your home office in one State, why would you be required to display that license there and not in the office in which you are lending in that State. You need to be more specific, as again I ask, what license are you referring too? Maybe giving us a State or two that you are licensed in might help also.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2277020 - 10/24/22 10:59 PM Re: Digital Picture Frame with multiple state licenses Compliance0411
Compliance0411 Offline
Junior Member
Joined: Jun 2022
Posts: 26
State licenses with the department of banking and finance which are required to lend in that state. We were informed that all licenses must be displayed in our home office (for all the various states in which we are licensed to lend.

Return to Top
#2277022 - 10/25/22 12:29 AM Re: Digital Picture Frame with multiple state licenses Compliance0411
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,363
Galveston, TX
Informed by who and what States? You continue to give us nothing to go on in helping you research the actual requirements. I think all of us would like to help, but you are not giving us much to go on. Without determining the State laws you are trying to comply with, how should we know what the requirement might be. If you are lending in 38 States, where the heck is your legal counsel in this question.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2277394 - 10/31/22 08:00 PM Re: Digital Picture Frame with multiple state licenses Compliance0411
Dan Persfull Online
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,025
Bloomington, IN
I have never heard of having to publicly display your banking "business" license. As Randy stated if it is required then it is a state requirement and not Federal. Generally if it is a state requirement you would only need to display the license for that state and not every state you are licensed in.

We have always been told by our regulators

Which regulators and what is their regulatory citation for such a requirement?

Dealing with 38 states I agree with Randy you most likely need to get your legal counsel involved.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2278028 - 11/18/22 04:20 PM Re: Digital Picture Frame with multiple state licenses Compliance0411
fmissle Offline
Diamond Poster
Joined: Jul 2007
Posts: 1,000
Pac NW
I think the issue here is that OP is a non-bank lender (from previous posts) and therefore would fall under different requirements than a bank.

Return to Top
#2278048 - 11/19/22 09:08 AM Re: Digital Picture Frame with multiple state licenses Compliance0411
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,363
Galveston, TX
Considering they said they need licensing in all of the States, I am not sure that any of us thought they were a bank. Banks are not required to be licensed to lend in any State of which I am aware. The questions presented by Dan and I remain unanswered.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top