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Ethics & Fraudeasy17% of exam

A lender's fair lending review discovers that their loan officers consistently require additional income verification from borrowers with foreign-sounding names, even when these borrowers are U.S. citizens with established credit histories. This practice would constitute:

Correct Answer

B) Disparate treatment based on national origin

Making lending decisions or imposing additional requirements based on an applicant's name, accent, or perceived national origin violates ECOA and the Fair Housing Act, even if the person is a U.S. citizen. National origin discrimination includes treating people differently because of their ancestry, birthplace, culture, or linguistic characteristics common to a specific ethnic group.

Answer Options
A
Reasonable due diligence for potential non-citizen applicants
B
Disparate treatment based on national origin
C
Acceptable risk management if applied to all foreign names
D
Legal verification procedures under BSA requirements

Why This Is the Correct Answer

Making lending decisions or imposing additional requirements based on an applicant's name, accent, or perceived national origin violates ECOA and the Fair Housing Act, even if the person is a U.S. citizen. National origin discrimination includes treating people differently because of their ancestry, birthplace, culture, or linguistic characteristics common to a specific ethnic group.

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