Answer:
Randy Carey
What you are describing is taking adverse action after considering credit related characteristic of the potential borrower. You cannot discourage applicants from applying for credit by prescreening them through use of their credit qualifications.
Answer:
Kathleen Blanchard
As mentioned, this is adverse action. Additionally, if the bank sets these requirements in policy as credit requirements in underwriting, the bank will need documented provable data (a demonstrable relationship) showing how these requirements demonstrate creditworthiness, particularly for homeownership. Why would the bank rule out creditworthy applicants simply because they do not own a home? Review the commentary to Reg B, 1002.6 re the effects test.
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