...few fair lending rules, if any, apply to business owners since they are assumed to be sophisticated users of banking services and don't need the protection of our regulators....
I am a bit concerned with all the discussion above because I haven't seen any mention of serving a majority of low to mod individuals or families.
Will you have the metrics to show that this program or programs serve LMI? Middle income people have less then perfect credit.
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.