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