Consumer Credit Policy · change request
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§4.2. Minimum credit score · 660 to 640
Requested: lower the minimum qualifying score for unsecured consumer loans from 660 to 640. Rationale from Consumer Lending: approval rate on customer applications between 640 and 659 at peer banks; loss experience on the 2024 pilot tier.
No conflict with Regulation B. A uniform score cutoff is a facially neutral criterion. Under amended 12 CFR 1002.6(a) a creditor may consider any information obtained so long as it is not used to discriminate on a prohibited basis, and the effects test no longer applies; comment 6(a)-2 still reaches criteria that function as proxies for a protected characteristic, and a score cutoff applied to every applicant is not one. Recommend approve.
· 91 Fed. Reg. 21620 (Apr. 22, 2026) · Supplement I, comment 6(a)-2
§4.4. Minimum income · $2,500 to $2,000 gross monthly
Requested: lower the minimum gross monthly income for unsecured consumer loans from $2,500 to $2,000. Rationale from Consumer Lending: customer income distribution in the 640 to 659 tier; the existing debt-to-income limit in §4.5 still applies.
No conflict with Regulation B. A dollar floor applied to every applicant is a facially neutral criterion, and lowering it widens access. 12 CFR 1002.6(b) bars taking a prohibited basis into account in evaluating income and limits how age and receipt of public assistance may be used; the floor does neither. The redline adds one sentence to the requested text: all verifiable income counts toward the floor, including part-time and public-assistance income, so the policy says on its face what 1002.6(b) requires. Recommend approve.
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CR-2026-018 · Opened Oct 5