Q: Do we have to include the Equal Housing Lender advertising
statement in a 15-20 second radio ad that briefly mentions that we offer mortgage
loans in addition to other products and services?
A: Yes. Under
both NCUA and HUD regulations, any advertisement for real estate-related loans
must prominently indicate that the credit union makes such loans without regard
to race, color, religion, national origin, sex, handicap, or familial status.
For oral advertisements (radio/TV), a credit union satisfies
the notice requirement by a spoken statement that the credit union is an “Equal
Housing Lender” (EHL) or an “Equal Opportunity Lender." And it doesn’t
matter how long the ad runs: there is no exception for ads that run less than
15 seconds like there is for the NCUA official ad statement (i.e., radio/TV ad
of less than 15 seconds don’t require the NCUA official ad statement – NCUA
Part 740.5(c)(7) and (8)).
For written and visual advertisements, a credit union may
satisfy the notice requirement by including the EHL or "Equal Housing Opportunity" (EHO) logo. Under NCUA’s
regulations, federal credit unions may use either logo/statement - NCUA Part
701.31(d); state charters must use the EHO logo/statement under HUD’s
regulations (24 CFR 110). See
also: June 18, 2012 CompBlog post: Fair Housing Act Posters: EHL versus EHO.