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September 16
S.A.F.E. Act - Auditing for Compliance;
Patricia Cashman

September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott

September 24
Using CPTED to Make Our Banks Safer;
Dana Turner and Carol Dodgen

September 30
Revised Escrow Rules - Review and Update;
Jack Holzknecht and Mary Beth Guard

October 7
CRA - Digging for Credit;
Patricia Cashman

October 8
Applicants and Applications: Knowing the Players and the Rules;
David Dickinson



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#1667856 - 02/21/12 02:04 PM Notice to Home Loan Applicants
Fluffy Is Me Offline
Platinum Poster

Registered: 09/08/09
Posts: 826
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?
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#1667955 - 02/21/12 04:15 PM Re: Notice to Home Loan Applicants [Re: Fluffy Is Me]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50003
Loc: Galveston, TX
Section 609(g)
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The opinions expressed are my own, take them or leave them.

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

Registered: 09/08/09
Posts: 826
Thank you. I don't even want to tell you how many times I went through that reg., and missed that!
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I don't need to walk a mile in your shoes; I can see from way over here that you're a total train wreck.

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

Registered: 09/08/09
Posts: 826
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.
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I don't need to walk a mile in your shoes; I can see from way over here that you're a total train wreck.

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

Registered: 08/28/02
Posts: 40710
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
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The opinions expressed are mine and they are not to be taken as legal advice.

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

Registered: 09/08/09
Posts: 826
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.
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I don't need to walk a mile in your shoes; I can see from way over here that you're a total train wreck.

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

Registered: 08/28/02
Posts: 40710
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.
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The opinions expressed are mine and they are not to be taken as legal advice.

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

Registered: 09/08/09
Posts: 826
thanks Dan
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I don't need to walk a mile in your shoes; I can see from way over here that you're a total train wreck.

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

Registered: 11/15/02
Posts: 16342
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.
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