Organizations must also review their rates structures to ensure they cannot discriminate against people for a basis that is prohibited or in line with the precise location of the home in breach of this Equal Credit chance Act (ECOA), the Fair Housing Act (FHA), or Massachusetts anti-discrimination and anti-redlining statutes, including G.L. C. 151B and c. 183, s. 64. The practice of billing overages (recharging an increased rate of interest, origination cost, or wide range of points on that loan for many borrowers than is charged when it comes to loan that is same with other borrowers in identical period of time) is allowed unless the training violates the ECOA or FHA. The lender would be in violation of ECOA and FHA unless the lender could show a legitimate nondiscriminatory business reason for the disparate treatment for example if members of a protected class under ECOA and FHA (including race, gender, age, etc. ) are charged an overage more often than other borrowers. Both the Federal Reserve Bank of Boston additionally the U. S Department of Housing and Urban developing have actually granted policy statements regarding the training of overages. 8 Management should review all policies and prices and payment structures to ensure these policies don’t produce a disparate effect, also for an unintentional basis.