Our credit card department would like to do a pre-screen offer to new bank customers obtained through a recent acquisition. However, they would like to exclude from the prescreen those bank customers who do not currently live in our "footprint." Is this ok? Any Fair Lending concerns? To my knowledge, we have never excluded for this reason from other prescreen campaigns.

Thanks in advance for any opinions on this!

There could be. I would look at the entire population of "new bank customers" vs the actual customers that would be in your "footprint". Do the excluded customers fit into any protected group? Check the census tract income levels of the excluded areas. Understand all those demographics and then give it the "smell" test. Understand the reasons why the credit card department wants to restrict the offering. Do they make sense from a Fair Lending perspective.

An example of a good reason might be, we want to confine the offering to the state of our home office, due to a lack of expertise in other states' requirements.

An example of a bad reason might be, we want to exclude the north part of the city because there are so many minority low income customers there.

If you end up with a plan to go ahead with the project, make sure the credit card department has documented the due diligence done and that risk management has been included. If the credit card department is not willing to put it in writing, then don't proceed.

Thanks GenerousLife! I should have been more specific on the "footprint." Our footprint includes states in which we have branches and bordering states. So we wouldn't be excluding certain tracts or parts of town, but entire states! For example, anyone currently living in California would not get the offer.