Tom provides good advice. You don't want to deny an unsecured request for insufficient collateral, none was offered. You don't want to tell them they need to provide collateral, if you don't accept it. What if he comes up with collateral? You still don't want the deal. Each of these could be deemed inappropriate in a Reg. B audit.
Terms and conditions and out of area are sufficient. Be sure the "area" issue is a policy you follow. This can be supported by CRA easily. Hopefully these are supported by your policy and practices.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell