Credit Discrimination: 2.2.4.4 Applicant Need Not Be Seeking New Credit
Applicants are not just persons attempting to open a new account. The statutory definition includes a person applying for an “extension, renewal or continuation of credit” and someone who “applies to a creditor indirectly by use of an existing credit plan for an amount exceeding a previously established credit limit.”109 The regulations clarify that the term also includes any person who has requested or received an extension of credit.110