04/15/2013
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 when pulling joint credit bureaus is concerned)?
03/11/2013
Where in the regulations does it specifically state that a credit report is only valid for 90 days?
02/18/2013
If a customer applies for an institutional CD and the bank finds the application to be ineligible/incomplete/denied, does an adverse action letter need to be sent for a CD application?
02/04/2013
In regards to FACTA and loan servicing: Are Servicers required to send a disclosure when obtaining a credit report for loss mitigation actions?
12/24/2012
I am renewing a loan that was originally a HELOC. The loan matured and I collected an updated "consumer HELOC" application and obtained a new credit report. The loan was approved for renewal but for a lower amount and shorter term. I was told that I should not have collected a new loan application (purpose on application was stated a renewal of HELOC) because this is not a new loan request. No new disclosures were required and only a simple form modification agreement was needed to renew the loan. Can you please advise as to what documentation would be need for this type of transaction?
10/15/2012
A new customer has presented his driver's license for CIP and a credit report is obtained. The credit report has his new address and "NO" address discrepancy red alerts show. Does this mean an address discrepancy has not occurred and the account can be opened using the address obtained?
10/01/2012
I work for a small community bank in West Texas and we are currently in discussions with our external auditors about whether or not we have to provide our customers with the Risk Based Pricing Notice. For all of our consumer loans, we do pull a credit report but a rate sheet is used to determine pricing and we do not pull credit scores. The credit report is only used to determine if we are going to extend credit to the customer, not what rate we are going to give them. We were under the impression that we did not have to give the Risk Based Pricing Notice to the customer if we are not using the credit report to determine pricing, but our external auditor is saying that we have to provide the notice to all customers that we pull a credit report on. Are we correct in not having to provide the notice since we don't use the report to price our loans or is our external auditor correct that if we pull a credit report we should provide the notice to every customer?
09/10/2012
If an existing checking account customer wants to open an additional checking account, do we need to run a credit report on them?
07/23/2012
Does the Fair Credit Report Act apply to Business accounts?
05/14/2012
My question deals with Adverse Action Notices...section # 5 the disclosure of use of information obtained from an outside source. I fully understand the first block for denials based on a credit report and all the information that now must be included. I am confused at the last box that is saying our decision is based on information obtained from another source other than a credit reporting agency. If we have to decline a client for the condition of their real estate and we received that information through an appraisal report should we be utilizing that box? Again this is when the denial decision was NOT based on any part of a credit report or credit score?