Lobby Signs for LPO

We just opened an LPO and I want to make sure we have all of the required signs. Here are my thoughts. Please let me know what you think. Thanks for your help.

1) CIP Customer Notice - Definitely need.
2) FDIC Official Bank Sign - Definitely not because deposits are not taken at the LPO.
3) Equal Housing Lender - Need it.
4) HMDA Notice - Don't need it. It is in an MSA, but it is not the Main Office or a branch. Is this correct?
5) CRA Notice - Don't need it. Again not a branch. Correct?
6) Funds Availability Notice - Definitely not.
7) Financial Disclosure Statement - No, because it is not a branch. Correct?

I concur with your thoughts. We have an LPO and that's how we do it.

You didn't indicate what kind of charter you are operating under. If it is a state charter, you will need to look to state regs on signage for "other" types of offices. Next door in Texas we have some specific regs on how to ID an LPO and disclosing where the home office is located.

Thank you both for your thoughts. It's always good to hear from a neighbor.

We are a state chartered, non-member bank (FDIC Regulated). I have our state's LPO Rules and I'm ok on their signage requirements. We have to make sure "Loan Production Office" is the same font size as our bank name on all signage and we have to display our LPO Certificate issued by the State. That's it, as far as the State is concerned.

My question was mainly about the Federal signage requirements. Thanks Anon.

While I agree with your conclusions, I would ask, why not put them there? Rather than having to educate/justify this to an examiner later who may ask, I'd put them up. That said, our branches/LPOs preferred to put everything in one large matted frame. This allowed consistency and was easy to manage changes, when needed. Certainly this may not be the case for all banks.

We did buy a 6 sign frame and put up 5 signs, leaving out the FDIC Official Bank Sign and the Funds Availability Notice. We also use this frame in our branches.

So, you're saying that we should just leave the 5 signs up? I've actually considered that, but I was afraid of an examiner asking the other question: "Why do you have these signs up when you don't need them?" I guess you can't be written up for posting more information than required, can you?

We should have opened a branch. Those I know about.

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You didn't indicate what kind of charter you are operating under. If it is a state charter, you will need to look to state regs on signage for "other" types of offices. Next door in Texas we have some specific regs on how to ID an LPO and disclosing where the home office is located.

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Don, Would you mind helping another Texan find those state regs on LPO's? We're about to open one and I could really use some direction... Thanks!