Fair Lending Requirements
Credit must be offered to all applicants fairly and consistently. Failure to do so may result in allegations of discrimination, potential violations of federal or state fair lending laws, litigation or reputational risk. All applicants should be encouraged to apply for credit without regard to any basis prohibited by law.
Prohibited bases include race, color, religion, national origin, sex, marital status, age, receipt of income (in whole or in part) from public assistance programs, or an applicant's good faith exercise of a right under the Consumer Credit Protection Act.
Taking and Processing Applications
All consumers should be encouraged to complete and submit applications for credit. Do not discourage anyone from submitting an application, either through oral statements, body language, delays or discourtesy. Also, make certain that employees provide a consistent level of service in responding to questions from consumers about the availability of credit and/or completing the application.
Responding to Credit Application Inquiries
Your employees should provide GECRB credit application forms to consumers and may assist consumers with the logistics of completing of the application (e.g. asking the application questions if the employee enters the information into a point-of-sale terminal, etc.).
A spouse only needs to sign the application if he/she is a co-applicant and wishes to be obligated to repay the debt. It is the consumer's choice to have a co-applicant. Alimony, child support or separate maintenance payments do not need to be disclosed unless the consumer wants this income to be considered.
Any questions regarding the credit program should be referred to your GECRB representative.