Fair Lending and Equal Credit Opportunity

1. The Federal Notice, and Why It Is Here

Banrox does not extend credit and does not decide anyone's application, so Banrox does not give the adverse action notice that a creditor gives. The notice below is the standard federal wording that 12 C.F.R. section 1002.9(b)(1) prescribes, reproduced so that you can read it before you apply anywhere. Every creditor you reach through Banrox must give you its own version, naming its own regulator, and that is the one that governs your application with that creditor.

Equal Credit Opportunity Act notice. The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided the applicant has the capacity to enter into a binding contract); because all or part of the applicant's income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal agency that administers compliance with this law concerning this creditor is [name and address as specified by the appropriate agency or agencies listed in appendix A].

The bracket at the end is the regulation's own instruction to the creditor, and it is left visible on purpose. Banrox is not the creditor filling it in, so Banrox does not fill it in. The formula reads "concerning this creditor", and a company that wrote its own regulator into that sentence would be telling you it is a creditor with a supervising agency. Banrox is not, and will not say that it is.

Where Banrox does sit under this law. Banrox regularly refers people to lenders, banks, card issuers and insurers. Under Regulation B, 12 C.F.R. section 1002.2(l), a company that in the ordinary course of business regularly refers applicants or prospective applicants to creditors, or selects or offers to select the creditors a request for credit may be made to, is treated as a creditor for two rules: 12 C.F.R. section 1002.4(a), which forbids discriminating against an applicant on a prohibited basis in any aspect of a credit transaction, and 12 C.F.R. section 1002.4(b), which forbids discouraging an applicant on a prohibited basis from making or pursuing an application. Banrox's marketplace does exactly what that definition describes, so those two rules bind Banrox, and Banrox intends to comply with them. Banrox is not a creditor for any other purpose: it does not underwrite, does not price, does not set terms, and does not approve or deny anyone.

If you want to complain about Banrox under this law. Write to [email protected]. You do not have to come to Banrox first and nothing here is a precondition. You can go straight to the Federal Trade Commission, Consumer Response Center, 600 Pennsylvania Avenue NW, Washington, DC 20580, or to reportfraud.ftc.gov, or to the Consumer Financial Protection Bureau at consumerfinance.gov/complaint. Those are the routes, stated as plain fact. They are not part of the notice above and Banrox does not present them as an agency's supervision of Banrox.

2. Who Actually Decides, and Who Does Not

Banrox does not approve credit. Banrox does not deny credit. Banrox does not set a rate, a fee, a limit, or a term, and Banrox does not underwrite.

Every decision about a loan, card, line, or account is made by the lender, bank, or issuer under its own criteria, its own model, and its own regulator. If you are declined, that company must tell you the specific reasons or tell you that you may request them, and it must name the credit bureau it used if the decision was based on a report. Banrox cannot obtain, explain, or reverse another company's decision, and any Banrox agent who appears to be doing so is exceeding their authority.

What a Banrox result means. Banrox does not use your credit report, your credit score, or anything derived from either, to decide which products you are shown, to rank them, to filter them, or to describe them. The comparison you see is built from the filters you chose and from the criteria the providers publish, and it would look the same for any two people who chose the same filters. Where a page says you "might qualify", that means the provider publishes criteria that your own stated answers appear to meet. It is not a pre-approval, not a pre-qualification by the provider, and not an offer of credit. Only the provider can pre-qualify or approve you, and only after its own review of an application you choose to make.

That limit is not a courtesy. The written instruction you gave Banrox authorises it to obtain your report so that Banrox can show it to you and alert you to changes, and 15 U.S.C. section 1681b(f) bars using a report for any purpose you did not authorise, not merely obtaining one. Building a shortlist of offers out of your file would be such a use. Banrox does not do it, and Banrox does not run a prescreened offer of credit or insurance. See Credit Data and Your FCRA Rights.

The one decision Banrox does make about you. Banrox decides whether to open and whether to keep your Banrox account, and an identity check and a fraud score feed that decision. Where a failed identity check is the reason, the check was generated from your credit file and Banrox owes you a written notice under the Fair Credit Reporting Act. What that notice contains, and how to ask a person to review the decision, is at Credit Data and Your FCRA Rights.

3. What Banrox Does to Keep the Marketplace Fair

• We do not collect race, colour, religion, national origin, sex, marital status, sexual orientation, gender identity, disability, or immigration status, and we do not ask for them. We cannot sort by a characteristic we do not hold.
• We do not use age, and we do not use receipt of public assistance, as an input to what products you are shown.
• Product ordering is driven by objective attributes: rate, fee, term, amount, and the filters you set. The full method is at Marketplace, Rates and Calculator Methodology.
• Payment from a provider cannot change ranking. Whether a provider pays Banrox is not an input to the ordering, and Banrox does not accept payment to change a rank, a badge, a rate or a summary. That is the rule Banrox holds itself to, and it is a rule rather than a physical barrier in the code. See Advertiser and Affiliate Disclosure.
• We do not vary price, product visibility, or service level by any protected characteristic or by any proxy for one, such as postcode used on its own.
• Where we use automated systems to rank or summarise, no such system approves, denies, or prices any financial product. See AI Features, Documents Lab and Automated Output.

4. Fair Marketing

Advertising for credit products carries its own rules. Banrox does not use audience targeting tools that exclude or include people on the basis of a protected characteristic, or on the basis of a proxy for one, in advertising for credit, housing, or employment related products. Where an advertising platform requires a special category setting for financial services advertising, we use it.

We do not run advertising that promises approval regardless of credit, that states a rate only available to a narrow group as though it were generally available, or that uses a triggering term without the disclosures the Truth in Lending Act requires. Where a provider supplies advertising copy that does any of those things, we do not publish it.

5. The Laws This Page Sits Under

• Equal Credit Opportunity Act, 15 U.S.C. section 1691, and Regulation B, 12 C.F.R. Part 1002
• Fair Housing Act, 42 U.S.C. section 3601, for housing related credit
• Truth in Lending Act, 15 U.S.C. section 1601, and Regulation Z, for how credit terms may be advertised
• Fair Credit Reporting Act, 15 U.S.C. section 1681, for adverse action and report use
• Federal Trade Commission Act section 5, and the Consumer Financial Protection Act, for unfair, deceptive, or abusive acts and practices
• California Unruh Civil Rights Act and the California Fair Employment and Housing Act, and the equivalent statute of every state where members live

6. If You Believe You Were Treated Unfairly

Tell us first if you want to, but you do not have to, and doing so does not pause any deadline.

• Banrox: [email protected], subject "Fair Lending Concern." We acknowledge within 3 business days and answer within 15.
• Consumer Financial Protection Bureau: consumerfinance.gov/complaint, or (855) 411-2372. Best route for a complaint about a lender or bank.
• Federal Trade Commission: reportfraud.ftc.gov. Best route for a complaint about a non-bank company, including Banrox.
• Department of Housing and Urban Development: hud.gov/fairhousing, for housing related credit.
• Department of Justice, Civil Rights Division: justice.gov/crt, for a pattern or practice.
• Your state attorney general and, in California, the Department of Financial Protection and Innovation at dfpi.ca.gov/file-a-complaint.

A full directory with addresses is at Complaints, Disputes and Regulator Contacts.

7. Servicemembers

The Military Lending Act and the Servicemembers Civil Relief Act give active duty servicemembers and their dependants rate caps, fee limits, and protections against certain collection and legal actions. Those protections are delivered by the creditor extending the credit, and any covered creditor must give you the required oral and written statement before you become obligated. Banrox extends no credit and therefore issues no such disclosure. If a provider you reached through Banrox failed to give you one, tell us at [email protected] and complain to the CFPB.