Equal Housing Lender Poster-Address

Posted By: Comp@2005

Equal Housing Lender Poster-Address - 05/29/12 08:03 PM

Since the CFPB assumed jurisdiction, the address required in some disclosures was modified.For example for ECOA notices. I would like to clarify however if the Equal Housing Lender poster required by the Fair Housing Act should also reflect an address change of the Federal Regulator Agency? I saw a rule published regarding this matter for Credit Unions, but nothing regarding large asset banks.
Posted By: upstateNY

Re: Equal Housing Lender Poster-Address - 05/30/12 03:58 PM

In addition, I see that the Poster was updated by HUD in 08/2011, which I was not aware of. Does anyone know if use of the updated poster is mandatory? If so, I've got a lot to replace.
Posted By: John Burnett

Re: Equal Housing Lender Poster-Address - 05/30/12 06:31 PM

Your Federal prudential regulator -- other than the OCC -- has its own regulation in this arena. OCC banks should be using the poster prescribed by HUD.
Posted By: upstateNY

Re: Equal Housing Lender Poster-Address - 05/30/12 08:57 PM

Originally Posted By: John Burnett
Your Federal prudential regulator -- other than the OCC -- has its own regulation in this arena. OCC banks should be using the poster prescribed by HUD.


John, not sure how to take your response. In addition, I noted afterwards that we post the "Equal Housing Lender" poster, which apparently has not changed.
Posted By: Reads Regs

Re: Equal Housing Lender Poster-Address - 05/30/12 09:09 PM

If you are a federal savings association supervised by the OCC, you should look at 12 CFR 128.5 .
Posted By: John Burnett

Re: Equal Housing Lender Poster-Address - 05/31/12 09:04 PM

Originally Posted By: COPR1
Since the CFPB assumed jurisdiction, the address required in some disclosures was modified.For example for ECOA notices. I would like to clarify however if the Equal Housing Lender poster required by the Fair Housing Act should also reflect an address change of the Federal Regulator Agency? I saw a rule published regarding this matter for Credit Unions, but nothing regarding large asset banks.


This has nothing to do with the CFPB, because the Fair Housing Act (under which HUD and others require the posters) was not transferred to the CFPB for regulation.

The NCUA relocated or renamed an office that handles consumer complaints for federal CUs, so it sent out an update, and reminded state CUs they need to continue complying with the HUD regulation.

The OCC doesn't have a rule covering national banks, so national banks should also be using the HUD poster.

The OCC does have a rule (cited in a post above) for federal savings associations, and also sent out a Bulletin (2011-41) advising national banks and federal savings associations of a relocation of its Customer Assistance Group (CAG), and telling federal savings associations to update their posters to list the OCC CAG and its Houston address.

State member banks use a poster required in a 1989 Board order, updated by a 2007 CA letter (CA-07-6) with a new address for its Consumer Help office in Minneapolis.

State nonmember banks follow FDIC rules at 12 CFR 338, with an updated Kansas City address supplied in FDIC FIL-18-2011 (3/25/11).

State savings associations follow FDIC requirements transplanted from the OTS to 12 CFR 390.146, which also includes the updated Kansas City address.
Posted By: Ms. X

Re: Equal Housing Lender Poster-Address - 04/29/20 02:31 PM

Hi John, Once a Federal Reserve regulated bank crosses over to the CFPB's supervision, does the address under the very last section of the poster ("Under the Equal Credit Opportunity Act, it is illegal to discriminate...") change to that of the CFPB or does that remain the Fed's address too (meaning the same Fed address listed in the top half of the poster under the section that states send complaints to HUD (with HUD address) and the Fed (with Fed address)? Thank you!