Is it acceptable for FIs to write off small dollar amounts?
We would like to start charging for credit report fees at our financial institution. Are there any fair lending considerations that we should be aware of (especially where pulling joint credit bureau reports is concerned)?
The new bank I am with gives Negative Information Disclosures with Adverse Action Notices. I don't see how this is correct since we have not issued credit to them therefore we have no negative credit to report personally. Am I correct? I've looked at FACTA and TIL and found nothing I can show the lenders.
A new customer has presented his driver's license for CIP and a credit report is obtained. The credit report has his new address and "NO" address discrepancy red alerts show. Does this mean an address discrepancy has not occurred and the account can be opened using the address obtained?
Does the Fair Credit Report Act apply to Business accounts?
This question is in regard to Consumer Loan applications (such as car/boat/RV loans and personal loans and non-dwellings related). Our Consumer Loan Division uses the credit score from a credit bureau as one of the input attributes to decision (approve, decline, or counter offer) an application. The Consumer Loan does not use Risk-Based-Pricing - in other words, for those applications that are approved, they all receive the SAME pricing terms (e.g. same interest rate). For declines, we disclose to the customers the Credit Score Disclosure that includes the 5 elements - (1) The actual numerical score used in the adverse decision; 2) The range of possible scores under the model used; 3) All key factors that adversely affected the credit score; 4) date score was extracted; and 5) the bureau used and contact as modeled after form C5. Our question is for those applications that are approved. Do we need to disclose the Credit Score Info? The argument for NOT needing the Credit Score Disclosure or RBP are these customers are approved and do not receive unfavorable terms. Should we disclose Credit Score Info even for applications that are approved (same as what we do for declines)?
In lieu of the risk-based pricing notice, we use the credit score exception notice. It automatically prints every time we pull a credit bureau report. I understand the purpose of the risk-based pricing is for lending, but we also use the credit bureau report to determine if we will open an account. Is it permissible to give this credit score notice with an AAN when denying deposit accounts?
How many days does a financial institution have to report a charge-off loan or credit card to the Credit Reporting Agencies?
Can you require someone to "un-freeze" their credit bureau in order to open a depository account?
I attended the Lending Compliance Roundup Seminar in Tulsa on March I. I understand that the easiest way to comply with the Risk Based Pricing Notice was to give the two pages from the credit bureau report- Your Credit Score and the Price You Pay for Credit. If we do give The Risk Based Pricing Notice stating that the interest rate would be effected, then must it be given to only the people it effects and not every customer?