Credit Report Fees and Fair Lending Considerations

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Question:

We would like to start charging for credit report fees at our financial institution. Are there any fair lending considerations that we should be aware of (especially where pulling joint credit bureau reports is concerned)?

Answer:

If you pull joint reports only on married couples and the cost is less than two separate reports that would be pulled on two non-married joint applicants, there is a risk that the regulators will see this as a disparate impact.

First published on BankersOnline.com 4/22/13