We'd like to offer an affinity program to local companies which will offer special pricing on various banking products for anyone employed by these companies. The program would offer lower fees on deposit products and discounted pricing on mortgages. The discount will be the same for all employees regardless of their position in the company. Does this raise any fair lending concerns?

Thanks

Only one.
Who picks out the companies that the special pricing will be offered to? If the companies are mostly white, in middle/upper income areas, etc. there may be an issue. What about the smaller company with a lot of protected class employees that has a meager account with the bank? Why are they excluded?

Unless open to all companies, and/or heavily documented, there could be a potential issue with disparate impact (effects test).