Click to return to BOL home page



April 22
A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina



Topic Options
#1667856 - 02/21/12 02:04 PM Notice to Home Loan Applicants
Poplar Offline
Platinum Poster

Registered: 09/08/09
Posts: 814
I am working on FCRA. I think I remember a notice had to go out if we run a credit report, whether denied or not. I can't find it in the reg. anymore. I keep finding Adverse Action, but not just a notice of the info in the credit report. Am I remembering something that isn't really there?
_________________________
Leave me out of it!

Top
#1667955 - 02/21/12 04:15 PM Re: Notice to Home Loan Applicants [Re: Poplar]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 48556
Loc: Galveston, TX
Section 609(g)
_________________________
The opinions expressed are my own, take them or leave them.

Top
#1668081 - 02/22/12 06:26 AM Re: Notice to Home Loan Applicants [Re: Poplar]
Poplar Offline
Platinum Poster

Registered: 09/08/09
Posts: 814
Thank you. I don't even want to tell you how many times I went through that reg., and missed that!
_________________________
Leave me out of it!

Top
#1668385 - 02/22/12 01:58 PM Re: Notice to Home Loan Applicants [Re: Poplar]
Poplar Offline
Platinum Poster

Registered: 09/08/09
Posts: 814
Here's another question. When a customer applies for an overdraft protection line of credit, our lenders pull the credit report, then send the Notice to Home App. That can't be correct, but not sure what should replace it.
_________________________
Leave me out of it!

Top
#1668416 - 02/22/12 02:53 PM Re: Notice to Home Loan Applicants [Re: Poplar]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 40014
Loc: Bloomington, IN
The NHLA is only for consumer purpose loans that will be secured by 1-4 residential real property.

If you use risk based pricing they should be sending the appropriate risk based pricing notice or the applicable exception notice.

See Subpart H

http://www.bankersonline.com/regs/12-1022/12-1022-000.html
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Top
#1668643 - 02/23/12 06:51 AM Re: Notice to Home Loan Applicants [Re: Poplar]
Poplar Offline
Platinum Poster

Registered: 09/08/09
Posts: 814
We don't use risk based pricing. I can't find anything about a credit transaction, not secured by real property, needing a disclosure. I think some disclosure to the consumer would be required since we pull the credit report. The application states it, but don't we have to send them a disclosure, once we pull it, with their scores? Adverse action disclosures are out there, but not just plain notices.
_________________________
Leave me out of it!

Top
#1668715 - 02/23/12 09:27 AM Re: Notice to Home Loan Applicants [Re: Poplar]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 40014
Loc: Bloomington, IN
If you do not use risk based pricing then there would be no "credit score" notice requirement for approved credit not secured by 1-4 residential real property.

For denials you would have to provide the credit score used in the decision on the AAN.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Top
#1668718 - 02/23/12 09:15 AM Re: Notice to Home Loan Applicants [Re: Poplar]
Poplar Offline
Platinum Poster

Registered: 09/08/09
Posts: 814
thanks Dan
_________________________
Leave me out of it!

Top
#1668782 - 02/23/12 10:18 AM Re: Notice to Home Loan Applicants [Re: Poplar]
RR Joker Offline
10K Club

Registered: 11/15/02
Posts: 15763
Loc: The Swamp
And be careful when you say you don't use RBP. If the lender takes into account credit, regardless of the score, and might bend the standard rate accordingly...in effect, you do RBP.
_________________________
My opinion only.

Say You'll Haunt Me-Stone Sour

Top


Moderator:  Jack/Pegasus, Mary Beth Guard