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#302713 - 01/12/05 06:44 PM
EHOL logo - ad clarification
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Anonymous
Unregistered
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Hi,
Searched the site and unless I missed it I don't think I saw specifically this question:
(we are an OTS regulated bank)
Do we need to have the doghouse (Equal Housing Lending Logo) on mortgage rate sheets that are available in the lobby for the customers to take with them? These are the ones that just list the rates and apy's on available loan products (not a brochure per se).
thanks.
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#302714 - 01/12/05 07:04 PM
Re: EHOL logo - ad clarification
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Gold Star
Joined: Jan 2004
Posts: 319
USA
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Since the sheets are available to customers, you should include the equal housing lender logo.
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#302715 - 01/12/05 07:08 PM
Re: EHOL logo - ad clarification
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Anonymous
Unregistered
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That would mean the doghouse as well as the text, correct?
THanks.
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#302716 - 01/12/05 07:11 PM
Re: EHOL logo - ad clarification
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10K Club
Joined: Oct 2000
Posts: 27,768
On the Net
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My understanding is the house plus the text is the logo required.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#302717 - 01/12/05 07:19 PM
Re: EHOL logo - ad clarification
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Anonymous
Unregistered
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#302718 - 01/12/05 07:22 PM
Re: EHOL logo - ad clarification
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Power Poster
Joined: Jun 2003
Posts: 7,758
Florida
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Anon, make sure to use the Equal Housing Lender wording. The subject line shows EHOL which may be referring to Equal Housing Opportunity - the renting/selling portion.
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#302720 - 01/13/05 04:10 PM
Re: EHOL logo - ad clarification
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Anonymous
Unregistered
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Hi again,
Could you please explain the difference between equal housing lender and equal housing opportunity? The rate sheet has been updated but they used "equal Housing Opportunity" and I guess that is incorrect? (This is for a mortgage loan rate sheet, OTS bank)
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#302721 - 01/13/05 04:28 PM
Re: EHOL logo - ad clarification
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Power Poster
Joined: Jun 2003
Posts: 7,758
Florida
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An oversimplification, but -
Equal Housing Lender is for people who make the mortgage loans, banks, credit unions, thrifts, etc.
Equal Housing Opportunity is for the real estate brokers, rental agents, etc. In the classifieds under home sales, apartment rentals, there would be the EHO. If you go to an apartment complex, the EHO sign is the one you would see.
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#302722 - 01/13/05 04:35 PM
Re: EHOL logo - ad clarification
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Anonymous
Unregistered
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Got it:) I will have the lending department fix our rate sheet.
Thanks for all help everyone!!!!
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#302723 - 02/16/05 08:22 PM
Re: EHOL logo - ad clarification
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10K Club
Joined: Oct 2000
Posts: 10,222
Toano, VA
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Quote:
As an OTS regulated institution, all advertising except for savings should have the EHL logo. See non-discrim rule at 12 cfr 528.4.
12 CFR Part 528.4 states:
"No savings association may directly or indirectly engage in any form of advertising that implies or suggests a policy of discrimination or exclusion in violation of title VIII of the Civil Rights Acts of 1968, the Equal Credit Opportunity Act, or this part 528. Advertisements for any loan for the purpose of purchasing, constructing, improving, repairing, or maintaining a dwelling or any loan secured by a dwelling shall include a facsimile of the following logotype and legend:" (image of doghouse goes here)
Where in this section does it say that an OTS-regulated institution must display the doghouse and legend on any ad other than one for housing-related credit?
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#302724 - 02/17/05 01:36 PM
Re: EHOL logo - ad clarification
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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According to this, EHL Q&A OTS does require it.  See page 2.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#302725 - 02/17/05 02:28 PM
Re: EHOL logo - ad clarification
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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I think the guru answers cited in DQ's post were unfortunately not specific enough. David's response (all ads except for savings) was closest, but even that wasn't accurate. The exact language of the regulation is cited earlier in this string, and that's what you should be following.
The OTS requires the logo and/or statement in ads for the types of loans described in the rule, and not for other ads.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8
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#302726 - 02/17/05 03:19 PM
Re: EHOL logo - ad clarification
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Diamond Poster
Joined: Apr 2001
Posts: 2,245
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Quote:
Where in this section does it say that an OTS-regulated institution must display the doghouse and legend on any ad other than one for housing-related credit?
The confusion here stems from the fact that the OTS revised this regulation recently. 12 CFR 528.4 did say until recently that all ads except for savings had to contain the logo, BUT on November 24, 2004 the OTS published the following in the Federal Register (see p. 68247):
http://www.ots.treas.gov/docs/7/73234.pdf
The effective date of the change was January 1, 2005.
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#302727 - 02/17/05 03:27 PM
Re: EHOL logo - ad clarification
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Bless you, Ted, for clearing up the confusion.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8
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