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?
We want to start a promotion where we notify customers that they have been pre-approved for a Home Equity loan, what guidance can you provide and what regulation should I look at?
Can you offer a special checking account to a select group of people, ie: they all work at the same place, without discriminating against other customers if they are not employed by the same company?
Our bank is considering a "club account" marketed towards young professionals. I know on the lending side we have ECOA and fair lending to take into consideration, what areas of potential discrimination should we consider on the deposit side? I have read the question answered by Andy Zavoina entitled Is Free Checking for 50 and older an ECOA violation? Are there other regulatory areas to take into consideration?
We will be offering CDs tied to money market accounts, both at premium rates, for a short time as a way to get new customers in the door. We do not want to offer these accounts to people outside of our geographic market area. If we have a "no out of area accounts at these rates" policy, are we required to disclose that in print advertising that only runs in our local area?