Our loan application asks for "Jr or Sr" as part of the applicant's name: "Name (Include Jr. or Sr. if applicable)". Is this a problem under Reg B that could promote discrimination on a prohibited basis?

An outside auditor raised this as an issue. Is the auditor correct - should we remove this?

This information is necessary to determine the identity of the applicant. Junior's credit could be quite different than dad's. I'd be shopping for a new "outside auditor" who understands lending and Reg. B.

I've seen Jr's up into their 90's, and Sr.'s in their early 20's.

It's a title, and does not reflect age - only having, or being a kid with the same name.

Actually, Sr. is not a legit title. Look at Jr.'s birth certificate for the name of the father and it will not have Sr. on it. Jr. just means that he was given the same name as his father. I am a Jr. and my father's name on my birth certificate does not state Sr.

Because he wasn't a Sr when he was born. He became one when you were born. Some opt to add the senior designation to their name when they name their son JR. Others simply carry the name with no designation. The point being made is that IF a designation is made, the application needs to capture it in order to properly pull credit, etc.