We make prescreened offers of credit for credit cards and exclude applicants over the age of 70 in our filtering criteria. What is a reasonable cut-off to not have a fair lending issue?

I've seen 115 as a cut off to help screen out possible fat-fingered entries. Otherwise, fair lending guidelines permit different treatment at age 62 as long as the treatment does not "disfavor" those 62 or older. Completely excluding those over 70 sounds like it could be disfavorable.

Link to similar question on CFPB's site:
http://www.consumerfinance.gov/askcfpb/3...quity-loan.html