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IR Pricing Exception for Competitive Disadvantage

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Question: 
On commercial loan requests we will sometimes deviate from the interest rates listed on our rate sheet (those rates offered to the general public) for reason of matching the rate being offered by a competing lender. We will report this as an interest rate pricing exception for reason of competitive disadvantage. My question is, does this same interest rate pricing exception constitute a Reg O violation when granted to a bank director?
Answer: 

It will unless you have comparable loan transactions. It will also be a fair lending concern for borrowers that may not be shopping or lack the sophistication to mention this fact.

First published on 03/29/2020

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