We are state nonmember bank regulated by the FDIC and our fully owned Mortgage Company subsidiary, is planning a name change.

My question pertains to their advertising and § 338.3(a)(1). Their new logo incorporates the new name (which includes the word "Mortgage") and in much smaller print underneath states "subsidiary of Our Bank's Name". Should this new logo include the EHL logo by default? It certainly appears to promote mortgage loans. Unlike the Official Advertising Statement on the deposit side, I'm finding no specific exclusions other than "in a manner appropriate to the advertising medium and format utilized." I'm concerned about signage and letterhead.

Can anyone please clarify?

Logo - letterhead?? I am confused. EHL is required when you advertise.