My involvement with these is minimal but I recall they were used as an enforcement tool during the blame game of mortgage losses during the last crisis. My question would be is this purely on the finance side or is there any fee for them passed to a borrower or applicant? (I'm not familiar with fees on them.) If there was a cost passed to the applicant, and the only branch doing this was in a minority area, and it was mostly or entirely those minorities paying the fees, I'd say there is a problem. If it is transparent to the applicant in the way they're treated and costs, I see little concern but you, management and counsel know your policies, products and vendors, I do not.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell