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#2298488 - 06/19/24 05:35 PM Fair Lending concern?
Anonymous
Unregistered

If 2 people proceed to open a joint checking account and only the initiator is able to receive a prescreen offer say for a credit card because of system limitations, would that be a possible fair lending issue as the secondary applicant will never receive an offer?

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#2298489 - 06/19/24 06:29 PM Re: Fair Lending concern? Anonymous
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 84,144
Galveston, TX
What do you mean the imitator? You mean like the first person listed on the account? Even in today's day and age a husband is usually listed first, so yes, it could have a disparate impact.
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#2298491 - 06/19/24 07:00 PM Re: Fair Lending concern? Anonymous
Rocky P Online
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Joined: Jun 2003
Posts: 7,720
Florida
Agree with Randy - definitely disparate impact issues.
Can the bank pull off of the CIF file instead of the deposit file. Each person should be independent there.
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#2298492 - 06/19/24 07:22 PM Re: Fair Lending concern? rlcarey
Anonymous
Unregistered

Initiator = primary.

Yes I am concerned the secondary can never receive an offer with the system limitations.

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