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#271272 - 11/17/04 09:44 PM Re: Notice to Home Loan Applicant & Credit Scores
Anonymous
Unregistered

I retract my call for help. Subsection (E) blush-blush

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#271273 - 11/18/04 02:04 AM Re: Notice to Home Loan Applicant & Credit Scores
Anonymous
Unregistered

I'm confused. Could you explain? Thanks.

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#271274 - 11/18/04 03:09 PM Re: Notice to Home Loan Applicant & Credit Scores
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
Quote:

You do have to provide the range of possible credit scores under the model used.



Amos...I replied to this yesterday, but it's not here...I was one-track-minded with my comment as I was on the mind-frame of the rules concerning credit scores used but not obtained by the CRA!!!

**To anyone that I sent a form too that uses the CRA score and not an internal score..just add the range and the date the score was created to that form and you should be fine with it otherwise.** Sorry!!!
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#271275 - 11/18/04 04:10 PM Re: Notice to Home Loan Applicant & Credit Scores
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
Quote:

I am intrigued by the thought process that we are not required to disclose range of possible scores, however I can find no support. Subsection (f)requires CRA's to disclose items (1)(A) thru (E). Subsection (g) requires mortgage lenders to "...provide...INFORMATION REQUIRED UNDER SUBSECTION (f). For lenders not using an automated underwriting system, I don't see exclusions for (B)(D) and (E). Help?



Paragraph (E)(ii) of section 212 says that: "This subsection shall not require any person to--
...

(ii) disclose any information other than a credit score or key factors, as defined in subsection (f)"

So in one place it says you need five items and in another place it says that you only need two of the five. I spoke with attorneys for both the FTC and FRB about this issue and they said this was contradictory in the statute and they couldn't really give advice about what to do!

The conservative approach would be to give all five. Bankers Systems will have the Notice to Home Loan Applicants and a separate credit score disclosure that will accomodate the five items. If you are using an automated underwriting system or a score from a source other than a consumer reporting agency, subparagraphs (B) and (C) only require the credit score and key factors.

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#271276 - 11/29/04 04:03 PM Re: Notice to Home Loan Applicant & Credit Scores
Anonymous
Unregistered

Fellow ARTA users - do you plan on giving the borrower both the REGV-HLA-NOT and the VMP-139. To complete both and give to the applicant would appear to be giving out redundant information. i.e. Borrower Name, Property Address, Credit Scores and Key Factors. The only additional information the VMP-139 gives is the Range of Credit Scores and the Date of the Credit Score. What are you fellow ARTA users planning to do for compliance with Section 212? Are you going to require that both forms be completed?

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#271277 - 11/29/04 04:08 PM Re: Notice to Home Loan Applicant & Credit Scores
bcastle Offline
100 Club
Joined: Nov 2003
Posts: 181
Springfield, Illinois (Souther...
I am sorry - I forgot to login when I made the last post...it is I, bcastle who posted "anonymous".
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