Can a bank offer different product offerings (from a Fair Lending Standpoint) to larger dollar borrowers that they do not offer to smaller dollar borrowers? All loans are business purpose.

What might the differences be besides amount?

Their total exposure would be the driving factor, those $1Mil and over would be offered the option to participate in a new product offering those under the $1 mil would not. Does that help?

I think what Rocky meant was what would the people with over $1MM exposure be offered over the other group. Offered "a new product" basically tells us nothing.