Equal Housing Logo Requirements

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Question:

Is it necessary to display the equal housing logo when not specifically referring to rates or terms in print advertising? If we are just saying: "Ask us about our loans...."? Is the logo always required?

Answer:

Housing related advertising should have the disclosure. That said, it is not an OCC requirement but is a best practice.

This is from Kirchman's BOB.

Fair Housing Advertising
Advertising. The authority for fair housing requirements in credit advertising is the Fair Housing Act. Historically, HUD has mandated the use and size of the fair housing, or “outhouse,” logo. HUD has dropped that rule. The current state of fair housing advertising is as follows:

OCC:

No advertisement or other published statement shall indicate any preference, limitation, or discrimination based on race, color, religion, sex, handicap, familial status, or national origin.

FDIC:

Written and visual advertisements must include the Equal Housing Lender logo and legend.
Oral advertisements must state that the bank is an Equal Housing Lender.
No advertisement shall contain any words, symbols, models, or forms of communication that express, imply, or suggest a discriminatory preference or policy of exclusion.

FRB:

Same as FDIC.

OTS:

No savings association may directly or indirectly engage in any form of advertising that implies or suggests a policy of discrimination or exclusion.
All written advertisements shall contain the Equal Housing Lender logo and legend.
Although the OTS regulation does not mention oral advertising, in discussions with us they have indicated they want savings associations to follow the FDIC and Fed position.

First published on BankersOnline.com 04/21/03