I have this request from a lender to further develop a relationship with a newly developed subdivision. What are your thoughts on this? Is there a way to do this and not run into any compliance issues?

We have a subdivision that we financed and want to put together some concessions that the real estate agent team can pass along to potential buyers.

Ideas would include
• Free appraisal
• ½% loan fee
• ¼% to ½% rate concession on construction financing

This would not be publicly marketed, rather just passed on by the realtor. It seems we investigated this a few years back on another subdivision and it became a fair lending issue.

Could we communicate something to the realtor?

IMHO, that is something the regulators would likely look at, especially if the neighborhood is not representative of all racial and ethnic groups. (Think redlining - think of the effects test). With the way the DOJ, CFPB and all other regulators are looking at lenders, the next question would be, why is that only in XXX tracts and not in the majority minority census tracts.