We like to put "Member FDIC" on our letterhead just to be sure. I can't find information on the Equal Housing Lender logo though and I wonder if it needs to be there?
Which Equal Housing logo is required for advertising by a mortgage broker? There are two logos, Equal Housing Lender and Equal Housing Opportunity.
We recently added a feature to our online banking and want to get the message out. We will do buck slips and hand them out to our customers as one way to get the word out. Are we required to add the FDIC and HUD logos to the buck slips we are handing out to our customers on a face-to-face basis?
We are looking into setting up a referral and rewards program for our HELOC Visas. We would like to both give our members a $50 gift card upon closing of a HELOC, as well as pay out $50 gift cards for referrals that end up booking. I hear different stories about limitations being either $25 or $600. Are there limitations? What would the dollar amount be?
We have a mortgage originator in our mortgage division that would like to enter a co-op advertising agreement with a builder in a new subdivision. The bank would like to commit approximately $1000 each month for advertising as the subdivision's exclusive lender. The advertising will consist of ads on signs, billboards and fliers listing the builder, one realty company and one lender. The bank's advertising budget will be reflective of the ads, i.e. if one-fourth of a $400 ad, the bank will pay $100 for their section. However, in order to spend the money on the advertising, the bank would like to recover the costs of the ads by deducting a portion of the advertising from the originator's commission payment. I get nervous anytime you mention putting a realty company and a mortgage lender jointly in an ad, due to RESPA concerns. Would this situation fall under the exemption in Sec. 3500.14 (g)(vi)? I also assume that we would need an agreement with our originators for recovery of the fees from their commission.
We handle FHA/VA loans where we do not make the credit decision. The Reg says we report HMDA if we make the decision, but HUD is telling us to report these in addition to the entity making the decision. Should we be reporting them in addition to the lender making the decision?
A mortgage company has approached our bank wanting to pay a specific employee a referral fee, if we would forward real estate loan applications we have turned down to them. I do not see how this is a legal process given Section 8 of RESPA's prohibition of referral fees. The only way I can see it would be legal, is if forwarding the application to the mortgage company would not be defined as a settlement service. I think it would be.
Does the Equal Housing Lender or Equal Housing Opportunity logo need to be used on a direct mail piece advertising the sale of homes, if the mailer comes from the builder and is listed with a realtor, but does not offer or talk about any type of loan?
The banking agencies released statements responding to consumers and lenders as the 90 day payment deferral period following Hurricane Katrina closed December 1.
Is it a RESPA violation to offer consumers a referral fee for referring a customer to a Bank for a home equity line of credit?