Lobby Posters in an LPO of a National Bank

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Question:

What lobby disclosures are required for a national bank for an LPO (loan production office) that does no retail (deposit) business? Equal Housing poster and what else?

Answer:

Because it is not a branch, it is unique. The EHL poster is the only lobby notice as it is under 24 CFR Section 110.15 requiring, "All fair housing posters shall be prominently displayed so as to be readily apparent to all persons seeking housing accommodations or seeking to engage in residential real estate-related transactions..." but also check state requirements.

Personally I would post all bank and loan related disclosures. I would not put up any thing pertaining to deposits to avoid confusion. I believe that the information the notices provide, annual disclosure availability, CRA notice, EHL poster, HMDA notice, etc. meet the spirit and intent of the regulations with little effort and maintenance. Then you don't have to split hairs with anyone over what is a "branch" for these purposes and you have made a full disclosure.

First published on BankersOnline.com 2/21/05