I've been asked if I see any problem with offering a 1/8 or 1/4% off of a loan rate for customer loyalty (long term relationship, details to be worked out, years etc.)My mind immediately thinks Fair Lending concern. Does anyone out there have a program like this?

Sounds like "relationship pricing"... is there any way such a program would have an adverse impact on any of the protected groups? That's the question that needs to be answered via your policies/practices and the way this program will be structured.

We do give a 1/4% off the loan rate to those loan applicants that have an existing deposit relationship with us. Longevity isn't taken into consideration though. It is part of our pricing matrix and everyone that is eligible receives it automatically. Our examiners have reviewed it without any concerns. Consistency is the key to avoiding the fair lending concern.

Consistency as well as clear definitions on what each term means - for example, does everyone calculate "long term relationship" the same?