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

January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson

January 22, 2015
Navigating the Treacherous Waters of IRA Rollovers, Transfers and Beneficiary Payouts
Patrice Konarik

January 28, 2015
Mortgage Life Cycle
Part I
David Dickinson and Jerod Moyer



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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: 51219
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: 41142
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.
_________________________
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: 41142
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: 16492
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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