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Marketing Based on Age-Fair Lending Issue?

One of the banks wants to conduct targeted mailings for a particular loan product based on the past history of the demographic that has bought this product in the past. In this case that would mean marketing to individuals based on age, over 50 years of age. Would this be a fair lending issue, marketing based on age which is a prohibitive basis?

Answer by Kathleen Blanchard: For a loan related product, Regulation B restricts age related terms to age 62 and over.

(o) Elderly means age 62 or older.


Answer by Randy Carey: If you are talking about using information that you have in-house, one specific target marketing mailing based on age would not be an automatic fair lending issue, if your overall marketing effort reaches all segments of your customer base. However, if you were pulling a prescreened list from a credit bureau, that is another story.

First published on 4/16/12

First published on 04/16/2012

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