Under the FCRA, do banks have to stop reporting a charged off debt to the credit reporting agencies after 7 years, or does the 7-year limitation only apply to the credit reporting agencies?
Our bank has a consumer line of credit product that is payable on demand with no set maturity date but there is an annual review. During the annual review, a credit report is pulled. We do not utilize risk-based pricing and have chosen to use the Credit Score Disclosure Exception Notice. Is this notice required in this case?
What regulations cover information for furnishers of credit information to CRAs. FCRA appears to cover the majority of it, but there is one section of Reg B (1002.10) that covers the requirements for reporting spouses. Are there any other regs that discuss the requirements of the furnishers of credit information?
When a customer files bankruptcy, can we report the loan as being charge off or does it have to be as bankruptcy?
When pulling a credit report on a consumer request, can we give the customer a copy of the full credit report or are we only allowed to give them a copy of the credit score disclosure?
I noticed on invoices on CBC credit bureaus the company is charging additional fees besides the cost of running the credit bureau. The fees include items like a $9 charge to update credit bureau records. $55 charge for something called 3 system residential mortgage. The bank passes these costs on to the customer on the GFE as credit bureau fees when the actual cost of the running the bureau is ~ $20.90. Should the bank be passing the extra charges from CBC on to the customers which do not appear to be costs of the actual bureau? No other credit bureau service appears to be adding charges to their bills.
When an originator takes a phone application, what is acceptable by the regulators that all the proper disclosures have been provided to applicant? My other concern is can we still pull a credit report with written authorization from applicant? ( This usually being provided by a signed application.) I was and still am under the impression that credit should not be pulled until you have an application.
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)?