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In Response To:
Thread Starter: Kathleen O. Blanchard
Title: Re: Prohibition against requiring loan payment via ACH

i agree with Brian. You can offer a car loan with a discounted rate for auto debit but must have an option for no auto debit.

Same for a HELOC or any other product.

You can't say "well we will only offer HELOCs with auto debit because we have other kinds of consumer loans without auto debit". The customer must be given a choice of auto debit or not for the kind of loan they are requesting, not some totally different kind of loan product.