The bank is looking to offer to make some loans to people who will now have to purchase property they were previously rent/leasing in one specific area of our market. In order to make it more attractive for these people to come in and apply, management is thinking about foregoing the normal $150.00 appraisal fee (always paid up front at application), until a positive credit decision is rendered (obviously subject to appraisal).

(Note: At this bank, all appraisals are done in-house by non-certified/licensed "insiders" unless the loan amount is covered by FIRREA)

The majority of people who would be applying are non-minority, middle to upper income individuals.

Since this appears to be a "specific marketing" issue, might it have a disparate impact?

Any input is appreciated.

How do you justify waiving this fee for these applicants and not other applicants for the same or similar type loan in a different market area?