Had a recent examination with the Credit Union League of Massachusetts in which they are asking us to put an ECOA disclosure on each desk in the organization where an application is taken. Does anyone have any information to substantiate or disprove this requirement. I have thoroughly reviewed Reg B. and see the content of the signage but can find nothing about where the signs must be located and how many need to be in the organization.

My first suggestion is that you contact the examiner and ask for his/her citation requiring this posting.

I suspect that the reference is to chapter 151B, section 7, Massachusetts General Laws. The MCAD used to have regulations requiring specific wording for postings under section 7, but those sections of 840 CMR have been repealed.

Thanks-actually already asked her what the specific reasons were that she wanted a sign at every desk where an application was taken. I think it is more her interpretation of the reg because we have had 50+ years of NCUA audits with no mention of this being a problem.

That's probably because NCUA doesn't know about the state rules in some cases. And it's my belief that the signs went out the window once the MCAD regulations were withdrawn.