205.10(e)(2) says you need to handle the "powers" delicately. They can't have their cake and eat it too. As it relates to employees having to use direct deposit:
Employment or government benefit. No financial institution or other person may require a consumer to establish an account for receipt of electronic fund transfers with a particular institution as a condition of employment or receipt of a government benefit.
As it applies to requiring auto-draft payments, they can't do that either. The cite above pertaining to compulsory use says that they can't deny the loan based on the fact that the borrower doesn't want this auto-draft.
The risk and employee grief isn't worth the minimal increase in profitability of these requirements. Again, you can price the products differently, but you can't condition the extension or employment conditions.
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Andy Zavoina
Opinions stated are not necessarily that of my employer.