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#2286917 - 07/24/23 04:26 PM
Re: FDIC FHA Signage
Noah Wiseman
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Platinum Poster
Joined: Feb 2003
Posts: 879
Big Sky Country
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From my FDIC contact: "We just found out that there was an error in the poster, so they pulled it to make the correction. Hopefully it will be back, and accurate!, very soon."
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Me, Type A? Maybe - I'm not done analyzing it yet.
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#2286920 - 07/24/23 04:38 PM
Re: FDIC FHA Signage
Noah Wiseman
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10K Club
Joined: Jul 2001
Posts: 84,246
Galveston, TX
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Error? Write them up
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#2286926 - 07/24/23 05:00 PM
Re: FDIC FHA Signage
rlcarey
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Platinum Poster
Joined: Nov 2010
Posts: 955
USA
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Error? Write them up Don't you wish we could?
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#2287618 - 08/14/23 03:12 PM
Re: FDIC FHA Signage
RebekahL CRCM
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100 Club
Joined: Aug 2006
Posts: 119
Massachusetts
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Yes, the FDIC needs to get their act together. The San Francisco Region just issued their Quarterly Newsletter (June 2023) and stated this: Updating Your Fair Housing Poster
In March 2020, the FDIC’s Division of Depositor and Consumer Protection consolidated the consumer and depositor assistance functions of the Consumer Response Center (CRC) and the Deposit Insurance Section into one organization, the National Center for Consumer and Depositor Assistance (NCDA). The FDIC officially launched the NCDA in May 2021. As a result, the FDIC modified several regulatory appendices and one citation to reflect the new name. Specifically, Appendix A to Part 1002, Regulation B - Federal Agencies to be Listed in Adverse Action Notices (12 CFR Appendix A to Part 1002 2.c.), Appendix A to Part 343 - Consumer Grievance Process (12 CFR Appendix A to Part 343), and Section 338.4 – Fair housing poster (12 CFR 338.4(b)), all include the new name, National Center for Consumer and Depositor Assistance. Due to this change, financial institutions will be required to update their Fair Housing poster. The mailing address, phone number, and web address for the newly named NCDA remains the same as the former CRC.
Division of Depositor and Consumer Protection National Center for Consumer and Depositor Assistance Federal Deposit Insurance Corporation 1100 Walnut Street, Box #11 Kansas City, MO 64106 Telephone: 1-877-275-3342 https://ask.fdic.gov/fdicinformationandsupportcenter.To request copies of posters, please refer to the FDIC's Banker ResourcesThe poster simply isn't there, and hasn't been for months. Does the Equal Housing Lender notice need to include "Division of Depositor and Consumer Protection"? This is not included in the model form text: https://www.ecfr.gov/current/title-12/chapter-III/subchapter-B/part-338/subpart-A/section-338.4
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#2287631 - 08/14/23 06:38 PM
Re: FDIC FHA Signage
Noah Wiseman
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Gold Star
Joined: Feb 2013
Posts: 441
Cape Cod
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Here's what that piece of the notice is supposed to include, according to the text of 338.4 that you linked to, Sgt. Pepper "AND TO: Federal Deposit Insurance Corporation, National Center for Consumer and Depositor Assistance, [FDIC-supervised institution should insert mailing address for National Center for Consumer and Depositor Assistance found at www.fdic.gov], https://ask.fdic.gov/fdicinformationandsupportcenter, for processing under the FDIC Regulations." The problem I mention above is that the FDIC has not updated its web page (the one linked in the regulation, and others) to provide the "correct" mailing address. That said, if you can't get the darned notices from the FDIC, get them from someone else and use the address that the SF office provided. I just don't understand why the agency has to make this so $&!@ difficult!
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#2287642 - 08/14/23 07:26 PM
Re: FDIC FHA Signage
Noah Wiseman
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100 Club
Joined: Aug 2006
Posts: 119
Massachusetts
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I reached out to FDIC and received confirmation that the correct contact information for the Fair Housing/EHL poster is: Federal Deposit Insurance Corporation National Center for Consumer and Depositor Assistance 1100 Walnut Street, Box #11 Kansas City, MO 64106 https://ask.fdic.gov/fdicinformationandsupportcenterI also asked about posters being unavailable to order through the FDIC online catalog and was told that an FIL will be published when they are available.
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Coming soon to a city near you: Sgt. Pepper's Overwhelmed Compliance Committee Band
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#2287645 - 08/14/23 08:03 PM
Re: FDIC FHA Signage
Noah Wiseman
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Gold Star
Joined: Feb 2013
Posts: 441
Cape Cod
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Someone at the FDIC must have had the bright idea that inserting an instruction in the regulation to use the address provided on the FDIC's website would make it easier to keep things current when they make the next change to the address or name of the unit at the FDIC without having to go through the hassle of publishing a Fed Register notice. Problem is, they haven't updated the info on their website to complete the job, so the SF office feels it needs to send out an advisory and people call the FDIC to get the info, and post in threads like this one.
I know that the FDIC has larger concerns than getting this right, but they could have made this easy instead of gumming up the works.
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#2288034 - 08/24/23 09:56 PM
Re: FDIC FHA Signage
Noah Wiseman
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Platinum Poster
Joined: Feb 2003
Posts: 879
Big Sky Country
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Game on again! The FDIC Online Catalog has the poster again. We'll see if it stays up. What were the errors, you ask? This is all I could find in comparing the two: July's 2023 version has sloppy centering and the address is not italicized: For processing under the Federal Fair Housing Act and to: Federal Deposit Insurance Corporation National Center for Consumer and Depositor Assistance 1100 Walnut Street, Box #11 Kansas City, MO 64106https://ask.fdic.gov/fdicinformationandsupportcenterFor processing under the FDIC Regulations Today's download fixed the centering, put the National Center on one line, and italicized the address:for processing under the Federal Fair Housing Act; AND TO: Federal Deposit Insurance Corporation National Center for Consumer and Depositor Assistance 1100 Walnut Street, Box #11 Kansas City, MO 64106https://ask.fdic.gov/fdicinformationandsupportcenter, for processing under the FDIC Regulations. That's it. It took them a couple months to clean up non-substantive formatting?!? eGads. Anyway, folks, there it is.
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Me, Type A? Maybe - I'm not done analyzing it yet.
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#2288233 - 08/31/23 03:49 PM
Re: FDIC FHA Signage
Noah Wiseman
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Diamond Poster
Joined: Jun 2006
Posts: 1,194
South
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Hot off the press: FDIC FIL-47-2023 published today. On April 23, 2023, the FDIC issued a Federal Register Notice to update and clarify the requirements for EHL posters that are required to be displayed in FDIC-supervised institutions. These changes were necessitated by a name change of the FDIC’s entity that receives complaints, from the Consumer Response Center to the National Center for Consumer and Depositor Assistance (NCDA), and the introduction of the web address of the FDIC’s web-based complaint portal. FDIC-supervised institutions are required to update their EHL posters with the following name, address, and web address: National Center for Consumer and Depositor Assistance Federal Deposit Insurance Corporation 1100 Walnut Street, Box #11 Kansas City, MO 64106 https://ask.fdic.gov/fdicinformationandsupportcenterThe effective date for these changes was June 23, 2023. Financial institutions are reminded that the NCDA’s address to physically mail complaints will be maintained at FDIC.gov, and EHL posters should reflect the correct address. FDIC-supervised banks may, but are not required to, obtain posters from the FDIC Online Catalog. Institutions may also wish to create their own posters or use third-party providers. Institutions are expected to make good-faith efforts to update the EHL posters as soon as reasonably practicable. To request copies of the EHL posters from the FDIC, financial institutions must be registered users of the FDICconnect (FCX) system and provisioned for the FDIC Online Catalog. The steps for FCX users to obtain posters are as follows: 1. To access the FDIC Online Catalog, log into FCX Connect using your FCX Connect credentials. 2. Once you are logged in, you will be redirected to the Business Center Menu. 3. Select the “Ask and Order” link on the upper left side of the screen. The FDIC Online Catalog link will appear underneath. 4. Select the “FDIC Online Catalog Link” and you will be redirected to the FDIC Online Catalog log in screen. 5. Click on the “FDIC Connect Users Click Here” button and you will be redirected to the FDIC Online Catalog.
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#2288312 - 09/01/23 08:23 PM
Re: FDIC FHA Signage
Noah Wiseman
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Diamond Poster
Joined: Apr 2013
Posts: 2,258
The West
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I'm in the FDIC Online Catalog and did a search using different words and still can't locate it. Has anyone been able to find it?
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#2288339 - 09/05/23 02:41 PM
Re: FDIC FHA Signage
TryingtoComply
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Power Poster
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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I'm in the FDIC Online Catalog and did a search using different words and still can't locate it. Has anyone been able to find it? Oh, good. I was starting to think it was just me. (But no, I can't seem to locate it, either. Been trying for a week now.)
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#2288344 - 09/05/23 03:23 PM
Re: FDIC FHA Signage
Noah Wiseman
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Platinum Poster
Joined: Feb 2003
Posts: 879
Big Sky Country
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While in the FDIC Online Catalog, click on "For Banks Only" on the left under "Categories". It is listed between "Deposit Insurance" and "Money Smart". The poster will then pop right up... it is one of only 5 items available for banks only (the others being two HMDA lobby posters and two Member FDIC signs). I had a coworker who could not find the poster either... turns out she did not have access to the "For Banks Only" Category. I bet that is happening to you too. Your bank administrator likely needs to change your access rights. I've successfully ordered a bunch, and anticipate receiving them this week. Yay? Good luck all!
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Me, Type A? Maybe - I'm not done analyzing it yet.
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#2288348 - 09/05/23 04:06 PM
Re: FDIC FHA Signage
Noah Wiseman
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Power Poster
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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My administrator can't find where to add access for me to "for banks only."
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You call it ADD. I call it multi-tasking.
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#2288363 - 09/05/23 05:55 PM
Re: FDIC FHA Signage
Noah Wiseman
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Platinum Poster
Joined: Feb 2003
Posts: 879
Big Sky Country
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You likely have to call the FDIC for help then. May the odds be ever in your favor.
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Me, Type A? Maybe - I'm not done analyzing it yet.
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#2288375 - 09/05/23 07:16 PM
Re: FDIC FHA Signage
RebekahL CRCM
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Power Poster
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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You likely have to call the FDIC for help then. May the odds be ever in your favor. LOL! Thanks!
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You call it ADD. I call it multi-tasking.
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#2289393 - 10/03/23 06:34 PM
Re: FDIC FHA Signage
Noah Wiseman
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100 Club
Joined: Oct 2007
Posts: 194
USA
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Did anyone notice that the Rule and the poster to purchase state: Federal Deposit Insurance Corporation National Center for Consumer and Depositor Assistance Federal Deposit Insurance Corporation 1100 Walnut Street, Box #11 Kansas City, MO 64106 https://ask.fdic.gov/fdicinformationandsupportcenterHOWEVER, FIL-47-2023 states: National Center for Consumer and Depositor Assistance Federal Deposit Insurance Corporation 1100 Walnut Street, Box #11 Kansas City, MO 64106 https://ask.fdic.gov/fdicinformationandsupportcenterThe first two lines are reversed! It seems a lot of vendors are going by the FIL. We use a vendor created magnetic tile and a change would cost us $$ to make it match the Rule and FDIC signage. Suggestions?
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#2289395 - 10/03/23 06:39 PM
Re: FDIC FHA Signage
Noah Wiseman
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10K Club
Joined: Jul 2001
Posts: 84,246
Galveston, TX
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Sure - move on. Any mail will get there regardless.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2289399 - 10/03/23 07:07 PM
Re: FDIC FHA Signage
Noah Wiseman
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Diamond Poster
Joined: Jun 2006
Posts: 1,194
South
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So we ordered our posters using the FIL procedures (above) and recieved them the week before last. They look like this. Federal Deposit Insurance Corporation National Center for Consumer and Depositor Assistance 1100 Walnut Street, Box #11 Kansas City, MO 64106 https://ask.fdic.gov/fdicinformationandsupportcenterHowever, in our FDIC Regional newsletter, received last week, it states the posters have to be worded like this. Division of Depositor and Consumer Protection National Center for Consumer and Depositor Assistance Federal Deposit Insurance Corporation 1100 Walnut Street, Box #11 Kansas City, MO 64106 https://ask.fdic.gov/fdicinformationandsupportcenterApparently this brings it in line with Appendix A to Part 1002 and Appendix A to Part 343 (which I have yet to check - I'm busy today!) Anyone going to reorder in light of this?
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#2289400 - 10/03/23 07:15 PM
Re: FDIC FHA Signage
Noah Wiseman
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10K Club
Joined: Jul 2001
Posts: 84,246
Galveston, TX
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You just reposted the same thing from above. Why would you go through that time and expense - the mail will get there regardless.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2289411 - 10/03/23 08:44 PM
Re: FDIC FHA Signage
Noah Wiseman
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Gold Star
Joined: Feb 2013
Posts: 441
Cape Cod
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The regulation lists the Federal Deposit Insurance Corporation on line one and the National Center for Consumer and Depositor Assistance on line two.
But FIL-47-2023 lists the National Center for Consumer and Depositor Assistance on line one and Federal Deposit Insurance Corporation on line two.
Lord knows how the address on the printed posters that were briefly available from the FDIC itself read.
Maybe they should change the name of the NCCDA again. Maybe they can get it right.
Frankly, I don't see how a bank can possibly get cited for using either one of those addresses. Pick one, get some sticky labels and get it done. Or wait until the FDIC warehouse says it has the right thing available.
This is some of what your bank's FDIC assessment goes for, folks!
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#2290276 - 10/31/23 05:49 PM
Re: FDIC FHA Signage
Noah Wiseman
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New Poster
Joined: Oct 2023
Posts: 11
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My Bank falls into the same umbrella of FDIC regulated, but also under CFPB supervision.
Within the Equal Housing Lender poster, there are two separate sections that state 'If you believe you have been disseminated against, you should send a complaint to (fill in the blank address). One section is for Fair Housing Act, and the other for the Equal Credit Opportunity Act.
Were you able to determine if the Equal Housing Lender poster should have the new FDIC complaint center (National Center for Consumer and Depositor Assistance) listed under the Fair Housing Act AND the ECOA section, or should we list the FDIC complaint center for one, and the CFPB complaint contact info for the other?
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#2290505 - 11/08/23 04:24 PM
Re: FDIC FHA Signage
Noah Wiseman
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Platinum Poster
Joined: Feb 2003
Posts: 879
Big Sky Country
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Comply2023, the CFPB does not have regulatory authority over the Fair Housing Act, which is still HUD's baby. (The Fair Housing Act was never moved to the CFPB for regulatory oversight like so many others, post DFA.) The original regulatory structure, therefore, remains unchanged, with each of the original agencies (FDIC, Fed, OCC, and NCUA) holding the implementing regs for HUD's Fair Housing Act rule. The CFPB is literally out of the picture on this one. In fact, you won't find anything about the Fair Housing Act or the EHL poster in the CFPB Exam Manual. You won't find any CFPB requirement for their address to be on the poster, because they don't have the authority to require it. That simply means your bank, as an FDIC-supervised institution (in part, anyway) follows the FDIC's regulation Part 338 for EHL verbiage. If you still have doubts about the address(es) to use, get in touch with the FDIC's official contact on the matter, as shown in the Federal Register announcement of the change. ( Here.)
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Me, Type A? Maybe - I'm not done analyzing it yet.
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