Is it permissible for our bank to offer a discounted mortgage rate if the customer opens a checking account and sets up an automatic payment?
Is it a violation of Reg B to favor a credit card application for a college student with no credit versus someone older with no credit?
You have a consumer that comes in wanting to apply for a loan. The consumer speaks no English. You have no one in your Bank that speaks the consumer's native language. The consumer has an acquaintance with them that is bilingual. We will say, for the sake of this discussion, that the consumer has adequate identification.On the one hand, if you so much as accept an application for the loan you are in jeopardy. You are at the mercy of the "translator" that they have with them and you have no way of knowing whether or not the consumer knows what information they are being asked to put on the application. You do not know if the consumer is there of their own volition or if they have been coerced by the translator. Even if it is all on the up and up, you don't know if the translator is competent to explain something as complex as a loan. And then you have the issue of if you choose to make the loan, in which case you have no idea whether or not the customer understands the obligation they have entered into and, of course, the litany of disclosures that are associated with the loan.On the other hand if you refuse to take an application, you risk violation of ECOA and Regulation B and God only knows what else for discrimination against a member of a protected class. It appears as though you have no good choice here.