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December 3, 2014
Overdrafts: Latest Regulatory Feedback, Guidance & Best Practices Webinar
David Dickinson and Jerod Moyer

December 4, 2014
Freebies, Bonuses and Contests
John Burnett and Andy Zavoina

December 9, 2014
Bankruptcy: Creditor Do's and Don'ts
Sam Ott

December 10, 2014
Branch Audits: What Is Going On Out There?
Patricia Cashman

December 11, 2014
Setting up New Accounts for Trusts
Mary Beth Guard

December 17, 2014
Integrated Disclosures - An Implementation Strategy
Mary Beth Guard and Jack Holzknecht

December 18, 2014
Loan Review Best Practices for a Community Bank
Bob Fritzlan

December 19, 2014
PREPAID PRODUCTS - Understanding the CFPB Proposal
John Burnett



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#1667856 - 02/21/12 02:04 PM Notice to Home Loan Applicants
The Minion Offline
Platinum Poster

Registered: 09/08/09
Posts: 830
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: The Minion]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50743
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: The Minion]
The Minion Offline
Platinum Poster

Registered: 09/08/09
Posts: 830
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: The Minion]
The Minion Offline
Platinum Poster

Registered: 09/08/09
Posts: 830
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: The Minion]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 41079
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: The Minion]
The Minion Offline
Platinum Poster

Registered: 09/08/09
Posts: 830
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: The Minion]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 41079
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.

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

Registered: 09/08/09
Posts: 830
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: The Minion]
RR Joker Offline
10K Club

Registered: 11/15/02
Posts: 16443
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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My opinion only. Not legal advice.

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