We have four branches located within a close range of each other but in two different states. We would like to market our loan origination fees for one state differently (lower) from the loan origination fees for the other state due to competitive reasons. Are there any discrimination or UDAAP issues with this?
If a bank targets a high net worth geographical are for a marketing campaign, are they up against any regs? Can someone define "Greenlining" please?
With the new cards being issued for Social Security payments, does the Bank have an obligation to do cash advancing for non-customers?
Does the Fair Lending Act limit the ability of a bank to use age as a targeting tool in direct marketing for loans?
The marketing department would like to offer deposit products that earn a higher APY to a wealthy neighborhood/area of town. They would earn a higher APY than our customers from other parts of town. Where can I find the regulations that show that this is discriminatory?
Among credit risk, market risk and operational risk, developing a good operational risk management program seems to be the most challenging. Can't our existing compliance processes (e.g., AML, Red Flags, GLBA, etc.) contribute to operational risk management?
We are thinking of offering new high rate savings accounts at only one of our branches. The branch is in a more affluent area than our other branches. Do you see any discrimination issues with this?
Are there any federal or state laws that prohibit a bank from hiring a potential employee due to a personal bankruptcy?
Would direct marketing to seniors for reverse mortgages be in violation of ECOA due to advertising to a particular group of people, in this case, age-related?
Our Reg E disclosure states that the limit for point of sale transactions is $500 per business day, however, we have officers that want to increase the limit for some customers. I am concerned about discrimination issues since the limit would not be the same for all customers. It would appear there could be other operational issues as well if there were unauthorized transactions or stolen cards. Are my concerns valid?