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#2190730 - 08/27/18 07:27 PM Social Media Ad Post
Anonymous
Unregistered

If a bank makes a social media post for example "check out our mortgage services" and includes a link to their mortgage site should the equal housing logo be included?

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#2190732 - 08/27/18 07:30 PM Re: Social Media Ad Post Anonymous
LiveFunLife Offline
Member
Joined: Dec 2017
Posts: 91
I believe so. Perhaps when a veteran replies take that info and run with it.

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#2190738 - 08/27/18 08:03 PM Re: Social Media Ad Post Anonymous
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,692
From 338.3 of the FDIC's rules:
(a) Any bank 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 bank makes such loans without regard to race, color, religion, national origin, sex, handicap, or familial status.

Your ad is "advertising" a loan "for the purpose of purchasing, constructing, improving.... etc," and therefore, is an advertisement subject to EHL rules. The EHL rules don't address links and web ads as the rules were written before that technology was around. Therefore, it is best to include it.

While not law, you could review the FTC DOT Com Guidance from March of 2013 which gives guidance for a "one-click" rule. That said, it is always better to include the EHL - which is my recommendation.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2190769 - 08/28/18 04:48 AM Re: Social Media Ad Post Anonymous
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,228
Toano, VA
Any electronic channel used for one-way broadcasts of information about bank products and services should be treated as an advertisement for any and all consumer protection regs unless there is a specific exclusion. What you describe is a billboard with a hyperlink.
_________________________
...gone fishing.

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#2190814 - 08/28/18 02:33 PM Re: Social Media Ad Post Anonymous
LiveFunLife Offline
Member
Joined: Dec 2017
Posts: 91
You rock Adam and Richard

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