Would there be any issues under UDAAP that any of you could think of, if a loan program were offered to give doctors a break on loan fees?

Why are you giving doctors a break in the loan fees? I can name you at least 3 area doctors that couldn't qualify for a loan to buy a gallon of gas. In fact one of them has just been sentenced to a term in prison for prescription trafficking for "pain" killers.

To go a step further. If my credit score is 800, my income is $175K my DTI is 10% and the Doctor next door credit score is 750, $150K income, DTI is 40%; why does he get a break in his loan fees simply because he's a doctor and I don't?

There have been fair lending discussions on this very topic in here that you can likely search for. They all have the same result, and then some, that Dan points out in this tread.

With anything UDAAP or Fair Lending related, you want to consider the impact based on an even playing field for all consumers.

A properly disclosed program such as this wouldn't face UDAAP violations unless you hid terms of the program or didn't disclose certain triggers for paybacks or things like that. It also won't face Fair Lending scrutiny unless it seems unfair to those not getting the break.

However on the fair lending issue, I would be prepared to answer the questions... why just Doctors? What specifically about them makes them good candidates for this fee break? What is the intended benefit to the bank of the fee break to Doctors? Why not all customers? How do you know they are Doctors? Do you mean all D.O.'s, MD's and DDS's? PhD's (like Psychiatrists or Psychologists)? What is the race, age, gender, income of the Doctors in our customer base? Where do the Doctors live relative to the rest of our customer base?

Answering those questions will help make sure the benefit of reduced fees you are giving to the Doctor's can't be construed as disparate treatment in terms of race, gender, age, income, address location, etc.

Again these programs are fine, but the UDAAP and Fair Lending rules mean, unlike in the past where bank's could do things simply because they made dollars and sense... we must now prove the sense regardless of dollars.

Cheers!

Thanks for the information.