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FDIC and Equal Housing Lender Information Relative to Advertising OREO Property

Question: 
If we are listing OREO property for sale in the newspaper, must we include the FDIC or Equal Housing Lender information?
Answer: 

Member FDIC is required for all advertisements that either promote deposit products and services or promote non-specific banking products and services offered by the institution. For purposes of §328.3, an advertisement promotes non-specific banking products and services if it includes the name of the depository institution but does not list or describe particular products or services offered by the institution. In essence, if the bank's name will be included in the OREO ad, it's a good idea to include Member FDIC. The Equal Housing Lender logo is required for any ad promoting consumer home loans. Since the new purchase may approach the bank for financing, it is a good idea to include the logo.

Vendor: 
Wipfli's Financial Institutions Practice has served the banking industry for more than 85 years. Our seasoned professionals have banking experience, dedicate their time to clients throughout the United States, and provide regulatory compliance, information technology, risk management, strategic planning, board development, audit, and tax services. Visit http://www.wipfli.com/fi, call 800.486.3454 or contact wipflifipractice@wipfli.com.

First published on 07/12/2015

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