12/19/2021
A creditor notified one of our customers that an online account was opened using their personal information. They didn’t open the account and informed that bank of the same. What else should I consider doing to help my customer?
12/05/2011
Can we pull a credit report on a customer without their consent? We have a customer who wants to consolidate some credit card debt. We told her that she needed a co-signer. She gave us her husband's social security number. Can we pull a credit report without his authorization?
12/06/2010
I've been talking with some co-workers in the Loss Prevention community regarding the use of a consumer report. I've been told by some people that it can be a very useful tool if you're trying to track down someone who owes your company money. They've also said that it's OK to use a consumer report without a customer's consent if the report is being used exclusively for customer who owes your institution a debt. Others have told me that under no circumstances should a consumer report be pulled without prior concent from the customer. What is the right answer? Are there good alternatives to using a consumer report?
03/29/2010
We have a mortgage preapproval program as defined by 203.2 - a preapproval program as a request for preapproval for a home purchase loan is an application under paragraph b(1) of this section if the request is reviewed under a program in which the financial institution, after a comprehensive analysis of the creditworthiness of the applicant, issues a written commitment to the applicant valid for the designated period of time to extend a home purchase loan up to a specified amount. Section 3500.2 defines an application as the submission of a borrower's financial information in anticipation of credit decision relating to a federally related mortgage loan, which shall include the borrower's name, the borrower's monthly income, the borrower's social security number to obtain a credit report, the property address; an estimate of the value of the property, the mortgage loan amount sought, and any other info deemed necessary by the loan originator. The six items to trigger a GFE requirement are property address, loan amount, monthly income, estimated value, borrower name, and social security. Since a property address is not known on a preapproval, is a GFE required? What if we request verification of income? Does that not trigger a GFE on a preapproval even if the property address is unknown?
02/15/2010
When is an application subject to RESPA, requiring disclosures to be sent? Is it when you have taken the initial 1003 by phone or email, or is it when you have a signed 1003 by customer and have verified income and assets, etc?
04/27/2009
How can I communicate compliance risk in terms that the business can understand and use to make immediate, measurable cost versus benefit risk decisions?
04/20/2009
How can I communicate IT risk in terms that the business can understand and use to make immediate, measurable cost versus benefit risk decisions ?
10/01/2008
By John Byrne, Bank of America
08/11/2008
A member's credit report came up with a social security number that was eligible for issue in 1987 and she was born in 1975. Also, there was suspected usage of the number in a death benefits claim for a man who died in 1971. I don't have access to the Social Security death list or identity check. Is there any other way to research this further?
08/04/2008
A member's credit report came up with a social security number that was eligible for issue in 1987 and she was born in 1975. Also, there was suspected usage of the number in a death benefits claim for a man who died in 1971. I don't have access to the Social Security death list or identity check. Is there any other way to research this further?