Our internal policy is that the credit bureau reports for individuals are used for one year to make credit decisions within that year. This being said, we provide the "Exception Credit Score Notice" provided by Equifax for credit reports pulled since January 1, 2011. Please provide some guidance on the following scenario: A new loan is being applied for on 01/14/2011 but we are relying on a credit report dated 08/20/2010. Is the "Credit Score Notice" in this case required?
If the bank does not charge the customer for a credit bureau report, must it be included on the GFE and HUD-1? If so, how is it disclosed?
I am wondering about the consumer disclosure aspect of the Fair Credit Reporting Act. Under time of notice, it says that one may report before or no later than thirty days after reporting it to the credit bureau. If I give them notice when they take out the loan, is that prohibited under the section 623(a)(7) B.2 (Time of Notice)?
Under Red Flag regulations, our bank uses credit reports to make loan decisions, but doesn't report to the credit bureau. Are we required to provide a notice of address discrepancy to CRA?
We are totally confused on the subject of the recent Credit Card Act. We are understanding that the TILA amendments apply also to our HEQ Lines of credit. We now mail statements at month end with a due date ten days from the statement drop and allow fifteen extra days to make payment without a late fee or any reporting to a credit bureau. Are we in compliance or must we make our payment due date twenty-one days or more for mailing purposes, and then, by contract with the customer, still allow the grace period?
Our bank routinely pulls credit bureau reports for all new loan requests. Although credit scores are only one of the criteria used to make a decision on a loan request, a poor score would weigh heavily on a credit decision. With regard to the FACTA provision of providing Credit Score Disclosures to residential mortgage loan applicants, a question arises about those applicants whose credit bureau we request and the report is returned without a credit score. The lack of a score is sometimes a factor in determining the decisioning of an application, the need for a co-signer, or even the interest rate that may be charged. Should a customer with a credit bureau history, but no score, be supplied with the notice?
Is it possible to add a written off checking account as a negative relationship on a credit report?
If, after being contacted, the guarantor does not cure a delinquency on a commercial loan are we allowed to report negative information to the credit bureaus?
When opening deposit accounts, our bank uses a minimum Beacon. Our system will automatically decline the account or the individual signer if their Beacon score is below our set minimum. We would then provide the appropriate adverse action notice. Our branches seem to think that everyone who has a Beacon Score above our minimum is automatically guaranteed a checking account regardless of any other factors. I know that if we use anything on that credit bureau report to make our decision we will have to give an adverse action notice, but can't we still use factors over and above the minimum score?
Can a car dealership give a copy of or show a customer his or her credit report?