Does it violate Regulation B (ECOA) to predetermine that all fixed rate loans made to individuals over the age of 60 will be sold on a secondary market?
Yes. While Regulation B does not specifically mention selling loans on the secondary market, the official interpretation to the regulation defines its scope to include all dealings between applicants and creditors, including the administration of accounts.
Age is included in the list of prohibited bases, and selling a loan on the secondary market is an administrative matter.
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