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The reasonable financing rules broadly prohibit two types of discrimination: disparate therapy and disparate effect.

The reasonable financing rules broadly prohibit two types of discrimination: disparate therapy and disparate effect.

Both theories may apply in some instances. Disparate therapy does occur whenever a lender treats a customer differently due to a characteristic that is protected. Disparate therapy ranges from overt discrimination to more subtle variations in therapy that will harm customers and doesn’t must be motivated by prejudice or perhaps an intent that is conscious discriminate. The Federal Reserve has made many recommendations towards the U.S. Department of Justice (DOJ) involving treatment that is disparate prices where bank employees charged greater fees or interest levels on loans to minorities than to comparably qualified nonminority customers. These recommendations have actually resulted in many DOJ enforcement actions.