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#336665 - 03/21/05 08:13 PM FDIC and Equal Housing Lender Logos
Anonymous
Unregistered

Ok, I didn't know where to post this, but does anyone know if the FDIC logo and Equal Housing Lender logo need to be on printed material for my bank's subsidiary escrow company?

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Lending Compliance
#336666 - 03/22/05 12:31 AM Re: FDIC and Equal Housing Lender Logos
homestar Offline
Diamond Poster
Joined: Feb 2001
Posts: 2,245
US of A
Without digging deeper, and making the assumption that you're a bank with a mortgage subsidiary...

Yes, you need the EHL logo. You should not use the Member FDIC bug if the ad is clearly being placed by the sub for mortgage loans.

If the ad is from the bank, then you do not need the Member FDIC unless you're also advertising deposits, but you can include it if you wish.
Last edited by Homestar; 03/22/05 12:32 AM.
_________________________
"If you want to tell people the truth, make them laugh, otherwise they'll kill you." ~ Oscar Wilde

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#336667 - 03/22/05 02:41 PM Re: FDIC and Equal Housing Lender Logos
SLU Voice Offline
Gold Star
SLU Voice
Joined: Apr 2004
Posts: 288
Hammond, LA
You need to include the Member FDIC in all ads for the bank save for the exceptions in the advertising regs. If you're advertising your bank, you're advertising deposits, unless, or course, you're adversiting a NDIP, in which case the reg prohibits the use of Member FDIC in advertising. The Equal Housing Logo need only be used when advertising loans.

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#336668 - 03/22/05 03:09 PM Re: FDIC and Equal Housing Lender Logos
Anonymous
Unregistered

We also place the Member FDIC logo on our stationery because our lenders and deposit folks write letter to customers on which they quote rates.

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#336669 - 03/22/05 11:35 PM Re: FDIC and Equal Housing Lender Logos
homestar Offline
Diamond Poster
Joined: Feb 2001
Posts: 2,245
US of A
I hate to be contrary, but here's what the FDIC regulation (12 CFR 328) lists as the types of advertisements that do not require the offical advertising statement. (Take a look at 12.)

(c) Types of advertisements which do not require the official advertising statement. The following is an enumeration of the types of advertisements which need not include the official advertising statement:
(1) Statements of condition and reports of condition of an insured bank which are required to be published by state or federal law;
(2) Bank supplies such as stationery (except when used for circular letters), envelopes, deposit slips, checks, drafts, signature cards, deposit passbooks, certificates of deposit, etc.;
(3) Signs or plates in the banking office or attached to the building or buildings in which the banking offices are located;
(4) Listings in directories;
(5) Advertisements not setting forth the name of the insured bank;
(6) Display advertisements in bank directory, provided the name of the bank is listed on any page in the directory with a symbol or other descriptive matter indicating it is a member of the Federal Deposit Insurance Corporation;
(7) Joint or group advertisements of banking services where the names of insured banks and noninsured banks or institutions are listed and form a part of such advertisements;
(8) Advertisements by radio which do not exceed thirty (30) seconds in time;
(9) Advertisements by television, other than display advertisements, which do not exceed thirty (30) seconds in time;
(10) Advertisements which are of the type or character making it impractical to include thereon the official advertising statement including, but not limited to, promotional items such as calendars, matchbooks, pens, pencils, and key chains;
(11) Advertisements which contain a statement to the effect that the bank is a member of the Federal Deposit Insurance Corporation, or that the bank is insured by the Federal Deposit Insurance Corporation, or that its deposits or depositors are insured by the Federal Deposit Insurance Corporation to the maximum of $100,000 for each depositor;

(12) Advertisements relating to the making of loans by the bank or loan services;
(13) Advertisements relating to safekeeping box business or services;
(14) Advertisements relating to trust business or trust department services;
(15) Advertisements relating to real estate business or services;
(16) Advertisements relating to armored car services;
(17) Advertisements relating to service charges or analysis charges;
(18) Advertisements relating to securities business or securities department services;
(19) Advertisements relating to travel department business, including traveler's checks on which the bank issuing or causing to be issued the advertisement is not primarily liable;
(20) Advertisements relating to savings bank life insurance.

I am not sure I agree with the blanket statement that if you're advertising the bank, you're advertising deposits. I think it's quite possible that an advertisement may relate only to loans and not deposits.
_________________________
"If you want to tell people the truth, make them laugh, otherwise they'll kill you." ~ Oscar Wilde

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