I would definitely lean toward fair lending, but I think the natural question you get from an examination team would be for you to successfully make the case for why $20,000 is your threshold. If you can make the case, you would likely escape criticism, but you need to know that is coming. How much is the card? Is there a profit margin that you need to hit to offset the cost of the card?
Cost of funds? Interest rate? Other fees?
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Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.
CRCM