FDIC Logo & EH Logo Left off of Promo Pens

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Question:

We give away pens with our name, logo, FDIC logo and Equal housing lender on them. We received an order today, and the company left off the FDIC logo and equal housing lender. Should we send them back or is it alright to use them?

Answer:

Since the pens, I presume, are not advertising any housing related credit product, the ECOA legend is not required. And if you'll look at the FDIC advertising provisions, Section 328.3(c)(10) specifically says that the FDIC advertising statement is not required on promotional items such as pens. Using the pens as they are will not cause you any compliance problems. You'll have to decide whether it is worth it to get what you ordered from the company.

First published on BankersOnline.com 04/24/06