Would you please give your opinions and compliance concerns to the following skip-a-payment proposal?
It will only be offered to accounts that are:
- consumer purpose non real estate
- Originated over a year ago
- No 30/60 delinquencies this year and previous year
- Fewer than 2 extensions last year
- Fewer than 6 extensions life to date
- Risk code < 5
- Originated in [state name redacted] branches
I see no concerns, with the possible exception of the qualifying risk code criterion. To the extent that has any correlation to a borrower characteristic that is a prohibited basis, I’d have fair lending concerns with the program. Assuming that there is no such correlation, I’d say the program appears to be compliant with Reg Z. You should discuss with legal counsel whether there are any state law issues.
Compliance Lifeline