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In Response To:
Thread Starter: BrianC
Title: Re: Prohibition against requiring loan payment via ACH

I think you are reading way to much into one word. The context of the statement in which it is located simply means that if I offer a loan program, say a fixed rate auto loan, and my base rate is 4.50% for a new 2018 car, I can offer a .25% discount and offer a 4.25% rate for loans with an automatic payment, provided that I also offer a fixed rate auto loan without an automatic payment at 4.50%.

If I offer a variable rate HELOC at Prime -.25% for automatic payments, then I must also have a HELOC product that offers a variable rate at Prime without automatic payments.

This requirement applies to any consumer loan program that is not an overdraft line of credit.