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#2229888 - 01/29/20 10:27 PM ITIN and Consumer Installment Loan
TeamComply Offline
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Joined: Aug 2016
Posts: 393
Applicant has an ITIN (no SSN), it is valid for three years from the date it was issued. Applicant is applying for a car loan, should we tailor our loan terms on the fact that this ITIN is only valid for two more years? Or should this have absolutely no bearing on loan terms?

Maybe the ITIN isn't the document we should be worried about (as far as how long the individual may remain in the US - what document is this, their visa/green card)? Question is if we have reason to believe the applicant may have limited time in the US, can we tailor our loan terms on this? or would this present fair lending concerns?

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Lending Compliance
#2230009 - 01/31/20 02:21 PM Re: ITIN and Consumer Installment Loan TeamComply
rlcarey Online
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Joined: Jul 2001
Posts: 77,216
Galveston, TX
These are all credit risk based decisions. Fair lending only comes into play if you treat similarly situated individuals differently. See 1002.6(b)(7) and commentary.
The opinions expressed here should not be construed to be those of my employer:

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