Considering that "retired" is (generally) 62 +, which falls under the definition of Elderly, I would worry about 1002.6(2)b iv
(iv) In any system of evaluating creditworthiness, a creditor may consider the age of an elderly applicant when such age is used to favor the elderly applicant in extending credit.
Then look just above it at the definition of the "Effects Test"1002.6 a (2)
Integrity. With it, nothing else matters. Without it, nothing else matters.