10/04/2015
If a borrower was denied credit for insufficient income (non credit score related),
does the credit /score disclosure need to be included with the denial letter?
09/07/2015
My bank offers consumer personal loans, and we recently hired a new underwriter for mortgage and consumer loans. Our new underwriter is saying that if the applicant shows no credit (no trade lines) from all 3 bureaus we must ask the applicant to supply us with four non-credit payment references. I know we have done this in the past for mortgages as we underwrite to Freddie Mac policies and this is one of their requirements to establish credit, but is this something that should be done for personal loans as well? We have never done this in the past.
07/12/2015
What regulations cover information for furnishers of credit information to CRAs. FCRA appears to cover the majority of it, but there is one section of Reg B (1002.10) that covers the requirements for reporting spouses. Are there any other regs that discuss the requirements of the furnishers of credit information?
09/29/2014
Credit Reporting: If we change a credit reporting status from current or account paid to BK or charged off, do we need to send the B-1 or B-2 notice pursuant to Reg V or some other type of notice that we are reporting negative information to the credit bureaus?
05/12/2014
When pulling a credit report on a consumer request, can we give the customer a copy of the full credit report or are we only allowed to give them a copy of the credit score disclosure?
04/21/2014
I noticed on invoices on CBC credit bureaus the company is charging additional fees besides the cost of running the credit bureau. The fees include items like a $9 charge to update credit bureau records. $55 charge for something called 3 system residential mortgage. The bank passes these costs on to the customer on the GFE as credit bureau fees when the actual cost of the running the bureau is ~ $20.90. Should the bank be passing the extra charges from CBC on to the customers which do not appear to be costs of the actual bureau? No other credit bureau service appears to be adding charges to their bills.
07/15/2013
When an originator takes a phone application, what is acceptable by the regulators that all the proper disclosures have been provided to applicant? My other concern is can we still pull a credit report with written authorization from applicant? ( This usually being provided by a signed application.) I was and still am under the impression that credit should not be pulled until you have an application.
05/13/2013
Our loan policy allows our loan officers to rely on a credit report for existing customers if the report is less than 1 year old. Should we be disclosing the original cost of the report as a POC item on the settlement statement?
04/22/2013
If I email the disclosures to the client and they acknowledge receipt, can I order the appraisal on the same day?
04/22/2013
We would like to start charging for credit report fees at our financial institution. Are there any fair lending considerations that we should be aware of (especially where pulling joint credit bureau reports is concerned)?