Coruscation

Signs of predatory lending include the lack of a fair exchange of value or loan pricing that reaches beyond the risk that a borrower represents or other customary standards.

• Furthermore, as outlined in the interagency Expanded Examination Guidance for Subprime Lending Programs,1 "predatory lending involves at least one, and perhaps all three, of the following elements:

  Making unaffordable loans based on the assets of the borrower rather than on the borrower's ability to repay an obligation;

• Inducing a borrower to refinance a loan repeatedly in order to charge high points and fees each time the loan is refinanced ("loan flipping"); or


• Engaging in fraud or deception to conceal the true nature of the loan obligation, or ancillary products, from an unsuspecting or unsophisticated borrower."