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#174365 - 03/29/04 06:51 PM fee reduction
Anonymous
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We are considering reducing our loan origination fee if the customer opens a deposit account. Is this allowable?

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General Discussion
#174366 - 03/29/04 07:09 PM Re: fee reduction
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
I can't think of anything preventing it. There's not a problem with anti-tying because it is a traditional banking product.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#174367 - 03/29/04 07:21 PM Re: fee reduction
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
If you have a large unbanked population that presents a prohibited basis disparity, you may want to make sure that you have your "business necessity" documented for fair lending purposes for the variance in pricing.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#174368 - 03/30/04 12:10 AM Re: fee reduction
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,754
On the Net
On the other hand, if you have well defined products to assist the unbanked, this may encourage them to be "banked" and provide home ownership incentives at the same time.

Fair lending wouldn't be my primary concern, but I would address it.
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AndyZ CRCM
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