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#1961374 - 09/11/14 07:54 PM Promotional Pricing for Lending
PNWcomplymi Offline
New Poster
Joined: May 2014
Posts: 15
The bank has instituted what management is calling "promotional pricing" for loans originated in five counties that are new markets for it. The business purpose has been defined as just that - to generate new business.

In doing that the rate sheets identify those five counties has having a .500 credit to the rate. If an applicant from outside those counties "asks" for the credit, because heard about it(I guess). The bank will honor that pricing in all counties.

Fair Lending/Fair Housing concerns??

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#1961405 - 09/11/14 08:29 PM Re: Promotional Pricing for Lending PNWcomplymi
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,259
Florida
You need to have it defined as to branches in the 5 counties, or people living in the 5 counties.

Reason, the definition may be critical during a fair lending exam. A bank I was at had a similar promotion. When the pricing fair lending sample was pulled by OCC, there was a large unexplained difference, until we referred them to the exact promotion (loans by branches within the area irrespective where the applicant lived).
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#1961407 - 09/11/14 08:30 PM Re: Promotional Pricing for Lending PNWcomplymi
Anonymous
Unregistered

Anon2 sez: U R not Anonymous, Anon.

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