Credit Report Constitutes an Application?

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Question:

When a credit report is obtained, does this constitute an application and become HMDA reportable?

Answer:

I think that you have the egg before the chicken. You need an application to have a permissible purpose to pull a credit report. Also, Reg B 202.4(c) requires a creditor to take written applications for the dwelling-related types of credit covered by Section 202.13(a).

First published on BankersOnline.com 6/25/07