Can we give coupons or gift certificates to our loan customers as a mailing or at settlement to some of the business establishments that are our customers?
Can we offer a different rate other than our standard rate for a specific direct mail loan campaign (i.e. Customers who receive this direct mail letter can get a loan at 7%, but anyone who walks in the door will get 7.25%).
I have been asked these questions and did not find anything in this forum, any thoughts, comments, problems?

The coupon idea is OK unless you are talking RESPA and settlement services.

Yes, special delivery methods and campaigns can have different rates so long as there is no discriminatory practice. That is, don't do a mailer to the country club members about a great deal if their membership is not representative of your customers demographics. I'd justify the offer in a business case proposal and retain it.

Thank you Andy, the coupons from what I am understanding is for local area resturants.

There are informal opinions from HUD under RESPA collected in the Barron & Berenson publication, "Federal Regulation of Real Estate and Mortgage Lending" by West Publishing that state that a lender can give a discount to its customer to get that cutomer's business, but not for referring others to the lender.

If the coupons are intended to reach consumers, Reg. Z's advertising rules will apply:
- rates must be quoted as APRs,
- trigger terms require an advertising disclosure, and
- expiration dates should be stated to avoid "bait & switch" (terms & conditions not actually available.)