I am looking for some input on different marketing techniques and any associated fair lending risks.
For example, say a lender partners with a company to provide certain "preferred" rates to employees of Company A. However, the rates and terms offered to employees of Company B are not the same, or as good.
Since we do not know the make up of each company according to prohibitied bases, would there be a fair lending risk with the two different loan programs described above? What if Company B ended up having a higher ratio of employees that fell under a prohibited basis in Reg B?