Strangely, ECOA may be your biggest risk. From the creditworthiness standpoint, CD-secured loans are almost 100% risk-free. Eliminating creditworthiness as a variable, regulators can do reliable file comparisons looking for disparities in pricing and other terms attributable to other factors--especially gender, marital status, race, and other prohibited bases. Your policy for these loans must be air-tight and you can afford no exceptions.
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...gone fishing.