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#1136597 - 02/26/09 05:11 PM FCRA - Use of Credit Report
King of Gray Offline
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Joined: Jun 2007
Posts: 49
NE
The question has been asked if it's permissible to share a credit report obtained for a credit loan application within the branch network. I believe the answer is no but having a hard time finding a reference in FCRA. There may be contract issues with this as well. Any thoughts?

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#1136637 - 02/26/09 05:40 PM Re: FCRA - Use of Credit Report King of Gray
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
For what reason are you "sharing" it?
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#1136645 - 02/26/09 05:44 PM Re: FCRA - Use of Credit Report rlcarey
King of Gray Offline
Junior Member
Joined: Jun 2007
Posts: 49
NE
My understanding is opportunities to cross sell

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#1136651 - 02/26/09 05:48 PM Re: FCRA - Use of Credit Report King of Gray
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,370
Galveston, TX
That would be an impermissble business purpose. You cannot use a credit report pulled to open an account (deposit or loan) for marketing purposes at a later date.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1138047 - 03/01/09 07:21 AM Re: FCRA - Use of Credit Report rlcarey
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Since FCRA does not have a commentary (you know, like a REAL bank regulation....), you have to look at the FTC Opinion Letters which are a bit haphazard to review, and a couple of them over-ride previously issued letters, BUT that is where you find the prohibition on using a previously pulled report for marketing purposes.

Here is the index of the Opinion Letters:
http://www.ftc.gov/os/statutes/fcra/index.shtm

The Gowen letter is the one that rains on the Marketing Parade:
http://www.ftc.gov/os/statutes/fcra/gowen.shtm
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Regulations are a poor substitute for ethics.
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