I went to a seminar this week and we were discussing ECOA issues and it was brought to my attention that if you provide rate concessions on loans for a certain class or group of individuals you are setting yourself up for unfair lending.
That got me to thinking. We recently started one of those 55 and older deposit account specials and part of the program is to grant more favorable rates on short term CDs for any accountholder in this group. Is there any similar problems with this as there would be on the lending side?