08/23/2010
If a customer executes his Right to Cancel within the allotted three days on a transaction, may we follow for reimbursement of the costs the bank incurred (i.e., credit report fee, flood, etc.)? May we follow for reimbursement of these costs if they cancel beyond the alloted three days? My manager wants me to collect for these, and I don't know if there is some regulation prohibiting us from doing so.
08/09/2010
Is the physical address of a consumer required to agree with an address discrepancy? Relative to sole proprietors, can a furnisher report a sole proprietor to the CRAs using the business address if it is different than the consumer's actual primary address? [John Doe lives here, but has a building across town where he does business.]
07/19/2010
Is it required to pull a tri-merge credit report on a consumer vacant residential lot or just improved residential property?
06/07/2010
If the bank pulls a credit report for hiring purposes, is the HR department required by law to have procedures in place to deal with address discrepancies?
06/07/2010
What kind of documentation does a bank need to retain in a file for compliance/auditing purposes to show that they had permission to pull a customer’s credit report prior to an application?
04/19/2010
Is a credit score disclosure required where no new credit report is pulled, but the lender is relying on a previous report containing scores already in the file (and for which a credit score was previously given)?
04/19/2010
A client submits a credit line application, but forgets to sign it. The client is notified via phone that the application is incomplete and a signature is needed. The client says he will come back the next day to sign the application. In the meantime, to expedite the process, the banker pulls the client's credit report. Once the credit report is pulled, it is seen that the decision will be to deny the credit due to the clients’ credit score and history. Unfortunately, the client never comes back to the bank to sign the application. Is the adverse action categorized as incomplete, since the client never signed the application, or is the application considered a denial, since credit was pulled and a decision made regardless of the application not being signed? Is a denial letter required to be send to the client?
04/12/2010
Will you explain the difference between a prequalification and a preapproval for HMDA, RESPA and OCC purposes?
04/12/2010
If the bank does not charge the customer for a credit bureau report, must it be included on the GFE and HUD-1? If so, how is it disclosed?
03/22/2010
Under new RESPA regs, is it ok to give a preapproval for a home loan with a property to be determined (TBD)?