Credit Discrimination: 3.4.4.4 “Applicant” Must Exercise the Rights
The applicant must have exercised the Consumer Credit Protection Act (CCPA) rights. “Applicant” is a defined term under Regulation B and includes a credit applicant, one who has been extended credit, and a co-signer or other party who is contractually obligated on the loan.136 If any of these individuals had previously exercised CCPA rights, the creditor may not use that as a basis for discrimination.