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Secondary Market Loans

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We currently sell loans to the secondary market. Since the loans take considerable time, we would like to set a minimum loan amount. Will there be any discrimination issues if we change our loan policy concerning secondary market loans to read that we will only process loans for the secondary market in excess of $50,000 or perhaps charge a fee if the loan is under a certain amount?

This action could have a disparate impact on protected classes, but that does not mean that you could not do it. You will just have to be sure that you have adequately documented your business necessity. Refer to the Appendix of the FFIEC Fair Lending Examination Guidelines under Special Analysis here.

First published on 4/20/09

First published on 04/20/2009

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