Fair Lending: Watch Your File Comments

The purpose of Regulation B is to …promote the availability of credit to all creditworthy applicants without regard to race, color, religion, national origin, sex, marital status, or age… and it is illegal to discriminate on the basis of any of these factors. File comments, however, can often unintentionally get lenders in trouble. We often run into situations where there was no intent to illegally discriminate but file comments give the appearance that these factors were, in fact, considered. Years ago, one of our consultants ran across a file comment, “nice balances for a young gal”. While the comment was actually intended to be complimentary of the applicant, it gave the appearance that the applicant’s age (young) and sex (gal) factored into the credit decision.

Jerod gives another example regarding religion in the video.


Fair Lending Resources!Published
2025/10/13

Jerod Moyer

Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!

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