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Is Direct Marketing to Seniors an ECOA Violation?

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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?

If the target group is elderly, as defined in Reg B (age 62 or over), you may direct marketing materials that otherwise comply with the Reg (and other applicable laws and Regs) without concern that you'll be cited for age-related discrimination. You are able to provide credit on more favorable terms to persons based on their age, if the qualifier has attained age 62 or more. You'd want to make sure that your materials don't run afoul of any state rules on reverse mortgage lending.

First published on 2/25/08

First published on 02/25/2008

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