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October 24
How to Audit Advertising - Compliance Issues Here, There, Everywhere!;
Patricia Cashman

October 29
Documenting an Applicant's Intent to be a Joint Applicant;
David Dickinson

November 4
Issues with Deceased Customers;
Mary Beth Guard and John Burnett

November 5
Vault Burglaries, Floods, Fires & Other Disasters;
Dave McGuinn

November 6
MLO v LO - Who Has to Do What?;
Jack Holzknecht and Mary Beth Guard

November 13
Domestic Violence & Workplace Violence: There Is A Link;
Shelly Collins and Dana Turner



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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: 828
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: 50412
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: 828
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: 828
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: 40974
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: 828
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: 40974
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: Fluffy Is Me]
Fluffy Is Me Offline
Platinum Poster

Registered: 09/08/09
Posts: 828
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: 16391
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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