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#460636 - 11/22/05 07:13 PM Folders used for new customers w/discl. inside
Miss Kitty Offline
Platinum Poster
Joined: Mar 2002
Posts: 721
California
Are lenders required to have the Equal Housing Lender/logo on the folders you send to your customers with the early disclosures/loan package?

I've seen some with, and some without. I've seen the exceptions to Advertising FDIC membership, but nothing excluding the Equal Housing Lender/Logo.

Thanks.

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#460637 - 11/22/05 11:51 PM Re: Folders used for new customers w/discl. inside
SavannahOne Offline
Diamond Poster
Joined: Sep 2005
Posts: 1,163
Georgia
My guess is that comes down to a case by case decision as to whether the folder could be considered an advertisement. Our folder, very plain, does not advertise anything. I would reassess, however, if we started to make it look like a brochure.

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#460638 - 11/23/05 03:39 AM Re: Folders used for new customers w/discl. inside
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,769
On the Net
The EHL rules for advertising depend on the agency. The OCC as an example, doesn't require it. But it is encouraged.

I would ask the purpose of the folder. If it is delivering disclosures for a requested loan, it is less of an advertisement and more of a response to specific terms. If it is sent cold, such as "see what you qualify for" then it is more of an ad, IMHO.
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