Our wholly owned Mortgage subsidiary wants to condition a loan on the applicant(s) paying for their loan with automatic payment from an account either with our Bank.

I don't see this as a violation of anti tying regs and I’m fairly confident it shouldn’t raise a red flag with regards to ECOA or FHA.

Does anyone see anything I may be missing?

It violates Reg E - 205.10:

(e) Compulsory use--(1) Credit. No financial institution or other person may condition an extension of credit to a consumer on the consumer's repayment by preauthorized electronic fund transfers, except for credit extended under an overdraft credit plan or extended to maintain a specified minimum balance in the consumer's account.

I looked through the Bank Holding Company Act and an FDIC Advisory Opinion but not Reg E.

Thank you for your help.

You can (and most banks do) give them an incentive to have the payment auto-debited, though. For example, give them a break on the rate, or waive a fee or something.