What is a loan application?
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?
Can a bank order a credit report for a customer without an extension of credit or opening an account and collect from them the pass-through fee?
Are there any penalties if an employee of a bank conducts a credit check on a non-customer without their knowledge or permission?
Can you run the name of an authorized signed on a business account through ChexSystems without obtaining approval? Or is the fact that he/she signed the signature card for the business account sufficient authorization?
Can we pull a credit report on a customer without their consent? We have a customer who wants to consolidate some credit card debt. We told her that she needed a co-signer. She gave us her husband's social security number. Can we pull a credit report without his authorization?
The commentary to Reg B and Reg V recognizes that the definition includes the phrase “arranges a loan” but also points out that in requiring credit score disclosures, section 1100F of the Dodd-Frank Act does not state that the credit score disclosures are only required for adverse action decisions related to credit. My question - we use eFunds/QualiFile which interfaces with TransUnion for both Debit and Credit information that translate to a score for opening DDA and SAV accounts. Are we now required to disclose in the same manner for denied DDA and SAV account opening requests?
FACTA describes certain requirements as it relates to consumer health records/reports. How does the Fed usually define "consumer"?
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)?
When denying a deposit account due to negative credit information, we supply to the customer a written notice of action taken. Within what period of time does that notice need to be given to the customer?