![]() ![]() The notice must incorporate either a facsimile of the logotype and language appearing in paragraph (d)(3) of this section or the logotype and language appearing at 24 CFR 110.25(a). The notice must be placed in the public lobby of the credit union and in the public area of each office where such loans are made and must be clearly visible to the general public. "(2) Lobby notice of nondiscrimination. Every federal credit union that engages in real estate-related lending must display a notice of nondiscrimination. 701.31 indicates NCUA's poster requirement only applies to federal credit unions - here is from Subsection (d)(2): Note:  NCUA did not make the distinction in their technical corrections but the existing language of 12 C.F.R.  State-chartered credit unions should look to the HUD's Equal Housing Poster in 24 C.F.R.  Part 701.31 only applies to federal credit unions.  The language for the updated poster can be found here.įederal Credit Unions. 701.31(d)(3) should be updated in the next couple of days.  This rule change was included in the Federal Register yesterday and the Electronic Code of Federal Regulations for 12 C.F.R.  In the past, the address was the Office of Examination & Insurance but it should now be NCUA's Office of Consumer Protection.  NCUA amended Part 701.31(d)(3) of their regulations to update the address that Federal Credit Unions are required to have on their posters.  One of these changes provides clarity for Federal Credit Unions in an area full of confusion since the creation of NCUA's Office of Consumer Protection:  the address required on the Equal Housing Lender poster.Įqual Housing Poster. The chances that your examiners will comment on your FHA logotype may be slim but in the event they do, the EHO logotype should be used by state charters while federal charters have the option to use either.Last Thursday, the NCUA Board approved a couple of Technical Corrections at their March Board Meeting. One item to muddy the water even further is that HUD actually repealed their FHA advertising rules (24 CFR 109) however, we recommend credit unions still rely on them for guidance. So what do you do if you are state charter? If you are a state charter you must follow HUD’s Fair Housing Act Regulations. If you read carefully 701.31 is specific to federal credit unions. With respect to written or visual advertisements, a credit union may satisfy the notice requirement by including a copy of the logotype, with the Equal Housing lender or a copy of the logotype with the legend Equal Housing Opportunity. Per NCUA Rules and Regulations 701.31 any federal credit union that advertises real estate-related loans must prominently indicate in such advertisement, in a manner appropriate to the advertising medium and format used, that the credit union makes such loans without regard to race, color, religion, national origin, sex, handicap, or familial status. I have conducted a few marketing presentations lately and one presentation slide that always seems to get a few questions from state chartered credit unions is the Equal Housing Opportunity (EHO) versus Equal Housing Lender (EHL) logotype.
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |