Learn More - Click Here!

New Reply Thread Options
#2252607 - 04/19/21 05:12 PM Loan questions
Anonymous
Unregistered

Marketing would like to do a promotion for Green Loan Products. If the customer purchases a hybrid vehicle or purchases solar panels for their home they would like to give the borrower a xx% discount in their rate. We currently give a % rate discount for auto deduct from a checking account. I was trying to find any information that this would not be allowed by Reg Z.

Return to Top Reply Quote Quick Reply Quick Quote
#2252611 - 04/19/21 05:16 PM Re: Loan questions Anonymous
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 5,839
Illinois
Reg Z just states what must be disclosed to the borrower. The bigger question is weather the practice is discriminatory under Reg B, which it isn't. Being non-energy conscious is not a protected class.

That being said, as with any special loan program you should evaluate it for any potential indicators of disparate impact. (For example if these products cost more than their traditional oil dependent counterparts, will minority borrowers be less likely to qualify resulting in white borrowers paying lower rates.)
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale