2. Offering a discounted origination fee for higher loan amounts (ex: - 0.25% for loans greater than $250,000)
IMO this will have a disparate impact on your low to moderate income borrowers depending on the demographics of your lending area.
1 % origination Fee.
$250,000 loan - $2500
$251,000 - $1957.80 (.25% discount for loan amount > $250,000).
Can you in reality present a business plan that it costs you $542.20 less to process the $251,000 loan vs. the $250,000.
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The opinions expressed are mine and they are not to be taken as legal advice.