Skip to content
BOL Conferences

Thread Options
#1807763 - 04/24/13 07:04 PM Notice of Action Taken
dog1 Offline
Member
Joined: Apr 2013
Posts: 54
Bucks Cnty, PA
On Part II - Disclosure of use of information obtained from an outside source.
If the reason for the denial is not due to a credit decision based upon information from a consumer reporting agency, this block should not be checked and the disclosure required from Dodd Frank Act will not fill. If the reason that the denial is for inadequate collateral or income would we check the second set of circumstances, when should we use the 3rd set of circumstances...there seems to be some confusion

Return to Top
#1807767 - 04/24/13 07:11 PM Re: Notice of Action Taken dog1
Beachbum, CRCM Offline
Platinum Poster
Joined: Dec 2006
Posts: 505
Knee Deep in Regs
If the reason for the denial is collateral value then you would not check the box for credit "decision based upon information from a consumer reporting agency". If the reason is income, It would depend on where you got the information you used to make that determination.
_________________________
What we think, we become.
Buddha

Return to Top
#1807773 - 04/24/13 07:17 PM Re: Notice of Action Taken Beachbum, CRCM
dog1 Offline
Member
Joined: Apr 2013
Posts: 54
Bucks Cnty, PA
If we do not adverse based upon credit do we need to enter the new disclosures as required by Dodd Frank

Return to Top
#1807780 - 04/24/13 07:24 PM Re: Notice of Action Taken dog1
Beachbum, CRCM Offline
Platinum Poster
Joined: Dec 2006
Posts: 505
Knee Deep in Regs
possibly, as an example, if you are basing the denial on debt ratio and you used the payment amounts from the credit report to determine that ratio, then, yes, you would include the Credit Agency imformation from FCRA/FACTA reg.
_________________________
What we think, we become.
Buddha

Return to Top