We have been providing the Notice of Negative Information at loan closing; however, I was told by an auditor that it is required to be provided on the notice we send when the borrower has defaulted. Is this accurate?
If you use a vendor that provides credit scores from all 3 bureaus and you only use the score/reasons from one bureau for the denial, do you use that specific bureau's name and address or the actual vendor that supplied the report for your adverse action notice?
For purposes of adverse action notices, on a loan application where the appraised value came in low, would the appraisal be considered information from a third-party?
Is the Telephone Consumer Protection Act even an issue today?
Our customer wants to buy a new lot on which they will put a mobile home they already own. We aren’t sure yet what we will secure the loan with, but what are some of the issues we'll have to deal with?
We are considering financing the purchase of mobile homes that will be placed in rental slots in a new mobile home park. Will we have to worry about complying with RESPA on these loans?
Our bank uses Chex Systems to help determine if we are going to
open an account for a customer or not. In our procedures, it shows we will
open an account unless Chex Systems Account Action reflects Decline, whether
or not there are closures for the individual. My question is, if we see there are closures, but the Qualifile Score happened to be in our acceptable range where it approves the account, are we still able to deny the account due to the Chex Systems results, or is this unfair practice? If we can't deny accounts due to closures that have an acceptable Qualifile score, can we rewrite the process to say any individual with an unpaid closure can be declined to make it fair?
If a borrower was denied credit for insufficient income (non credit score related),
does the credit /score disclosure need to be included with the denial letter?
Is an FCRA Notice required when denying a request for an increase in the amount of credit on an Overdraft Credit Line? The decision was based upon the customer not meeting the minimum credit score requirement to move to the next line size.
Is Chex Systems considered a credit reporting agency? If we are using their scoring as part of our decision to open a checking account, do we owe them disclosures similar to the disclosures issued when we pull a credit bureau?