We are opening a new bank and I want to ensure all the required lobby and ATM notices are displayed. I went to the archives from Banker's Action 1996 and found the article pertaining to the required notices. Have there been any updates to this or is there a more recent article which states all the required lobby notices? Is there any regulation or publication that states all the required lobby and ATM notices?

[This message has been edited by lpstark (edited 09-19-2001).]

I have a signage worksheet you can review, download and customize as you see fit. Cites are included.

Check it out. I only ask for an e-mail of feedback.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

Andy - in your worksheet you state that the Equal Housing Lender poster should be "Displayed in each bank lobby and where..... or loans made." I was thinking about this and wanted to get some thoughts. In our bank we do have this poster in our bank branch locations. However, we have different physical business units that do accept loan applications (i.e. private banking, corporate banking, commercial real estate). Should each of these areas have this poster in their location? Thank you.

I would. This poster is required under 24 CFR 110.25. While it isn't exactly clear since they didn't use the word "and", look at 110.30.

"A failure to display the fair housing poster as required by this part shall be deemed prima facie evidence of a discriminatory housing practice."

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

Just to be on the safe side, we make sure a poster is in each branch manager's office. It may be overkill, but the sign doesn't take up that much space. Better safe than sorry.

I think that a Fair Housing poster in my office is WAY over kill. Besides, it doesn't go well with my decor.

The regulation only requires that it be posted in the lobby where deposits are made and where home loans are made. One outside of the loan officer area is sufficient - not inside of each office.

I thought I rememembered reading where the OCC goes by the HUD rule for the Fair Housing Posters. I know with FDIC banks (12 CFR 338.4), you can use either the Equal Housing Lender or the "Equal Housing Opportunity" (HUD) poster.

So, If the OCC uses the HUD regs allowing the one poster which has the Washington and the Regional office on, why do we have the Fair Lending poster with the "new" OCC Customer Assistance address in Houston? Maybe this was a custom-made thing?

The FDIC regs explicitly state that their poster is an exception by 24 CF 110.15(b). I haven't found anything from the OCC stating that any other than the HUD poster was authorized.

Thanks for any help!

The poster from OCC has the HUD address on it for reporting discrimination complaints to HUD in DC and also includes the OCC customer complaint address in Houston for routing complaints for possible enforcement action. As I recall, that process is centralized and that's the address that should appear. The poster also includes the ECOA statement and the address there is the Houston address per Reg B.

Thanks!
I looked up Reg B, but there seems to be no posting notice for the ECOA statement. The main reason I asked was that our bank has been posting both posters, and, by the regulations, only the HUD one was mandated in OCC banks by the HUD reg.
I found out a number of interesting things by researching- the only liability it seems (as far as the OCC states in the Comptroller's Overview Handbook) is that if someone files a complaint against the bank with HUD, it may be "prima facie evidence of a discriminatory housing practice." From their Fair Lending Handbook, they do not cite poster noncompliance as a violation becaue HUD does not recognize it as a FH violation.
So, my take on this is that the FDIC poster (with Reg B notice added) is OK for non-FDIC banks, as long as the consumer division address is correct for that agency, and they also post the HUD Equal Housing Opportunity Poster. FDIC banks can post either one.

As I recall each of the agencies in teh FFIEC has their own address on their version of the poster, as allowed them by HUD. So there is a prescribed format and size.

Why wouldn't you want it posted?

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

In our OCC bank branches, we post both poster - I was trying to find something in writing by the OCC that we can use either poster.
I just reread 24 CFR 110.25- it may be that because "a" regulatory agency (FDIC) provided a substitute poster, the waiver and poster apply to any agency. In that case, we need only display either one.

[This message has been edited by Chris W (edited 01-28-2002).]