When sending a negative information disclosure for FACTA Section 212, does a notice need to be sent to each individual on the account? A compliance source stated that a negative disclosure needs to be sent to each individual on the account, in separate envelopes.
Has a model form been issued for the FACTA Risk-based pricing notice yet? We just starting using credit scores for our loan pricing and want to be sure we have all of the proper disclosures.
I am in the process of updating my loan policy to reflect recent changes to FACTA and predatory lending. I was going to just add a general statement to the policy stating that we comply with the changes in the FACT Act. Should I elaborate more in my policy and do I need to outline the entire Act in my procedures? What recent changes that I may have missed that need to be added to adjusted to my policy?
Under FACTA, would a Notice To Home Loan Applicant and associated credit score information be necessary on a loan to finance construction of the consumer/borrower's primary residence?
Can our Lending department use a credit report from our mortgage department to offer a pre-approval Home Equity to a customer? Is there a section in the FACT Act that addresses this and can you refer me?
Under the FACTA, if a residential mortgage loan applicant has no credit score (a non-resident alien, for example), would the Notice to Homeowner and disclosure requirement be waived?
If we do not report any negative information for loans or credit cards what parts of FACTA are important for us to comply with?
During several phone seminars regarding the FACT Act, reference has been made to a provision on the Act which will deal with requiring procedures for "employee misconduct investigations." However, now that regulations have started coming out re: the FACT Act, this reference to "employee misconduct investigations" seems to have vanished from the lists of what is or will be covered by the FACT Act regulations. Could you clear this up for me?
Add "V" to Your Regulatory Alphabet
by Mary Beth Guard
The FACT Act gives consumers a right to a free copy of their credit report once each year.