09/27/2010
I have a prequalification (no property address) and ran joint credit (husband and wife). The husband’s credit scores are too low, but the spouse's scores meet investor guidelines. I have a credit analyzer tool that we have available through our credit bureau and I am working with the husband to try to increase his scores. At the same time, I’m getting a VOE on the spouse to see if she will qualify on her income alone. If the husband's scores cannot be improved, can he be removed from the loan, or will I need to do a declination and start over with just the spouse? Also, I have another loan that is joint and the borrowers qualify; however, the spouse's credit score is somewhat low and this affects the rate the borrower can obtain through our investors. The borrower wants the spouse removed from the application. Would we have to withdraw this loan and start with a new loan or can the co-borrower be removed without having to withdraw the loan and start over?
06/14/2010
On April 12, there was <a href="http://www.bankersonline.com/compliance/guru2010/gurus_comp041210d.html">a question</a> concerning credit bureau reports and how to disclose them if the lender does not charge for a credit report. The answer was that it should be listed in Block 3 and a negative amount in Block 2. Which line would we check in Block 2? Why would this be shown as a negative amount on line 802, when the charge isn't for a specific rate but for a credit report? The answer didn't address the fact that the lender doesn't charge for a credit report. If we don't charge, do we still need to include it in Block 3?
08/24/2009
Is flood insurance required on a property that the bank has foreclosed on and now owns? Notice of Default was filed, but we have been unable to sell the property. The loan balance has been turned over to the credit bureau for collection.
03/09/2009
Do any privacy regulations require advance notice to report loan experience to the credit bureau? Can the customer opt out of such reporting?
01/05/2009
We have a customer who did not take advantage of the Servicemembers Civil Relief Act. We are reporting delinquent payment history on his credit report and he is disputing the information to the credit bureau. Are we allowed to report the delinquent history to the credit bureau?
09/08/2008
Do we need to produce the Notice to Home Loan Applicant if we are only doing an interim construction loan for a residential homestead? We are not doing the permanent financing, does that matter? We did pull a credit bureau on the borrowers.
03/03/2008
An auto dealer takes a credit application from a consumer, pulls a credit bureau report and submits to a captive lender. After 45 days from the credit application being submitted, the captive lender rejects the credit. While still trying to get the consumer financed, the credit is submitted to two other lenders three months after the original application was received. Both lenders reject the credit. Ultimately, 3 1/2 months from the date the credit application was received, the captive finance company buys the deal. Did the dealer violate any laws by not obtaining a new credit application from the consumer because so much time had passed before the deal was bought?
11/27/2006
If you turn a consumer down for a loan and the consumer asks for a copy of the credit report that the lender pulled, can you give him a copy? Where is this located in the Reg?
02/13/2006
On GFE, if the bank charges one fee and disburses to the credit bureau, flood certification provider, and appraiser does each provider have to be listed on the GFE?
09/19/2005
An FDIC examiner suggested that the bank develop a written procedure for responding in a timely fashion to consumer disputes concerning credit report information. Is there such a checklist available outlining steps in response to a credit dispute?