What issues do I need to review with regard to a 0% consumer lending program for state employees. My first throught was Fair lending, but we wouldn't be discriminating on a prohibited basis. Any thoughts would be appreciated.

If you are a state bank, be mindful not to lend to any state bank examiners.

There has to be more to this story. Why would a bank ever consider such a product offering. The regulators are going to have a fit.

I would think that in Springfield, Illinois you would have a gluttony of state employees. Would that be a significant chunk of your loan portfolio? I would be concerned about safety and soundness issues. You can only give away so much free money before it affects your bottom line.

Of course, the state legislature can never agree on a budget. Right now there is a very good chance that state employees will not be receiving a paycheck next week. Perhaps bcastle is doing a short term loan until they receive their paychecks?