06/18/2012
Assume that a credit report was pulled on our customer on January 25, 2012, and a loan was funded at that time. The customer comes back on April 14, 2012, to get another loan. If we used the same credit report originally pulled on January 25, 2012, to base our approval on the second loan, should the loan Officer send the customer a second Credit Score Exception Notice using the same information that was given to the customer on January 25, 2012? Should each new loan have a "new" Credit Score Exception Notice as part of the loan package? Our officers are just copying the "old" notice and inserting it in the new loan package. Our LaserPro documentation allows us to put the date of the new loan application (04-14-2012) but the officer is just copying the old notice with the application date of the original note.
03/19/2012
Do the adverse action notices need to be sent individually to each applicant or can they be sent together if it's a joint application?
02/06/2012
We are wanting to close LOCs that have remained dormant or inactive for longer than 24 months. Does this require an adverse action notice? If so, do we need to include the new credit report key factors?
01/09/2012
If 3rd party fees were collected at application and the loan is denied and an adverse action notice is sent out, do the 3rd party fees collected need to be refunded if the services were provided (credit report and appraisal)?
01/02/2012
Recently, an LO with poor judgment ran a credit report on a woman after an application from a man who claimed to be her husband, but key here is he was not going to be a co-borrower, he said his credit and income were bad, only his "wife" would be on the loan. Statement of Credit Denial went out, Risk Based Pricing Notices went out, woman is very upset. We ran her credit and says she is not married. Obviously, we goofed and there is peril here. What about joint applications where we speak to only one party and ask permission for pulling credit? Do we have to ask both parties if it is OK to pull credit?
12/12/2011
Once we pull a credit report and have a full application, do we have to send the early disclosures despite the fact we are going to decline the loan for insufficient income for the credit amount requested?
10/31/2011
Is it necessary to run credit on a non-borrowing, non-owner spouse in a community property state mortgage loan?
10/31/2011
Can the preliminary docs on a 1-4 family be dated prior to the Notice to Home Applicant? The credit report was not drawn until after they signed preliminary docs. We do not use credit scores as a basis for approval or interest rate.
10/24/2011
Why is the credit report fee pre-paid on non-real estate loans and and not pre-paid on real estate?
09/05/2011
Can you deny a loan before having the customer fill out a loan application and pulling a credit report?