I'm reviewing a new loan program where the Bank will work with a pool dealer and do the financing of pools for referrals from the dealer. The risk assessment that was done indicates that the pricing will vary for customers and non-customers of the Bank. For example, a HELOC will have a rate of WSJ Prime + .5% for customers and WSJ Prime + 1.5% for non-customers. I don't know if this would have fair lending implications but I would like any thoughts or compliance issues on the pricing difference. Thank you.

C. Nakashige

Relationship pricing has been around for years. There should be no fair lending issues as long as the policy is applied consistently.