...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.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.