Banker's Compliance Consulting Blog

Fair Lending: Watch Your File Comments

Written by Jerod Moyer | Oct 13, 2025 7:17:27 PM

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.


Published
2025/10/13