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Is there any fair lending risk associated with consideration of foster care payments as income, assuming the applicant provided it voluntarily?

Generally, no, assuming the consideration is made for all similarly situated applicants. Yet it could raise other compliance issues, such as that under §1002.5(d)(2) in Regulation B addressing reliance on alimony, child support, or separate maintenance payments, as well as §II.A and §II.E under Appendix Q in Regulation Z. (June 2020)

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