No Loans to Non-US Citizens, Disparate Treatment?

Answered by:

Question:

Is it disparate treatment to have a policy stating that the bank does not do loans for non-US citizens?

Answer:

The Official Staff Interpretations to 202.6(b)(7)(2).

2. National origin — citizenship. A denial of credit on the ground that an applicant is not a United States citizen is not per se discrimination based on national origin.

HOWEVER, although the applicant could not bring a discrimination complaint under Reg B, they very well could file a complaint under the Civil Rights Act.

First published on BankersOnline.com 02/27/06