EHL Symbol Required on Social Media Post?

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Question:

We are an FDIC regulated bank. If we post a picture on social media of customers that have just closed on a home loan, and we are congratulating them, is it necessary to include the EHL symbol or can we just have the EHL words included in the post?

Answer:

The first thing you need to ask yourself is: Is this "any form of advertising". If you cannot answer that "no", then the logo is required on any visual advertisement.

§ 338.3 Nondiscriminatory advertising.
(a) Any FDIC-supervised institution which directly or through third parties engages in any form of advertising of any loan for the purpose of purchasing, constructing, improving, repairing, or maintaining a dwelling or any loan secured by a dwelling shall prominently indicate in such advertisement, in a manner appropriate to the advertising medium and format utilized, that the FDIC-supervised institutions makes such loans without regard to race, color, religion, national origin, sex, handicap, or familial status.

(1) With respect to written and visual advertisements, this paragraph (a) may be satisfied by including in the advertisement a copy of the logotype with the Equal Housing Lender legend contained in the Equal Housing Lender poster prescribed in § 338.4(b) or a copy of the logotype with the Equal Housing Opportunity legend contained in the Equal Housing Opportunity poster prescribed in 24 CFR 110.25(a) of the United States Department of Housing and Urban Development's regulations.