Our vendor's form is designed to be signed by the borrower. Since there is no requirement (yet) to have the form signed or retained, we developed our own form with no signature lines. Our written policy and practice, as well as our form should be enough to demonstrate compliance. When a credit report is obtained, the form is completed by our underwriting department, the staff of which never sees the customer face to face. It's a tri-fold document that goes into a window envelope. They simply drop it in the mail the same day the report is obtained and compliance is complete.
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The more you sweat in training, the less you bleed in battle.......