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#289254 - 12/15/04 02:50 PM Branch Audit
KYAuditor Offline
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KYAuditor
Joined: Jan 2003
Posts: 138
Kentucky
This may sound like a dumb question, but here goes. We have a limited services branch that does not take loan applications or originate any loans. The only loan-related service is accepting loan payments. Is the Equal Housing Lender poster required for this branch?
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Audit
#289255 - 12/15/04 03:25 PM Re: Branch Audit
Jokerman Offline
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Joined: Nov 2003
Posts: 12,846
Never been an issue for me since we don't have branches that don't originate loans, but here's the FDIC exam guidelines:

Quote:

Determine that...the poster is...
11 x 14 inches in size
Conspicuously displayed in a central location within the bank where deposits are received or residential real estate-related transactions are made (338.4), and
The Equal Housing Lender poster contains the correct text in the proper format of 338.4(b) or 24 CFR Part 110.25(a) for HUD’s Equal Housing Opportunity poster.



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#289256 - 12/15/04 07:50 PM Re: Branch Audit
KYAuditor Offline
100 Club
KYAuditor
Joined: Jan 2003
Posts: 138
Kentucky
Thanks, Jokerman. I wasn't sure what they meant by real estate-related transactions. I looked up the definition in the regs and they don't appear to include accepting loan payments. However, we are going to display the poster anyway. Better to have it and not need it than to need it and not have it.

Thanks again!
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Just my 2 cents worth--for what its worth!!

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#289257 - 12/15/04 08:01 PM Re: Branch Audit
Jokerman Offline
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Joined: Nov 2003
Posts: 12,846
Well, I was keying on the fact that it was to be in either a location where deposits were made, or one where r/e transactions are made. But the reg may give a lot more background.

You're right - just put it in them all and then you have nothing to worry about.

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