Our bank offers an affinity credit card program wherein we brand the cards, but do not own or service the cards. When we implemented this program, there was some regulatory action out there where, I think, banks were being cited for providing guarantees for select customers, so we are refraining from doing so. The question has come up again, and I am not finding anything relating to this on-line Does anyone have any information to help guide me? Maybe I'm just thinking too hard, but I thought this was a Fair Lending issue of guaranteeing some but not all cards (UDAAP as well??).

Sounds more like an issue of properly accounting for the contingent liability.

Too much water under the bridge since this was last visited - I also had thought of the accounting for liability aspect. Appreciate your input.