What might happen if we don't have a system to track complaint resolutions?
We recently switched credit bureau vendors. This vendor automatically includes the credit score disclosure exception notice with the credit report. We in turn provide this disclosures to those who apply for consumer credit. There are times when a lender will use a consumer report for a business purpose loan. If we provide the credit score disclosure exception notice on a business purpose transaction/application are we asking for trouble with examiners? Could we be subject to fines?
If we take a loan app over the phone, web page or in person, how long do we have to keep each?
We are having an issue with our application giving a compliance error when the 30 days past due is not taken into account on the payment history. Can anyone direct me to a rule/regulations concerning calculating the days past due for credit reporting?
If an account is due on April 1st and it was reported on April 30th then it is only 29 days past due so it is reported as a current account with an Account Status of “11 – Current Account (0-29 days past the due date)”..
If it is not paid in May, on May 31st it is now 60 days past due. The account status would then jump to “78 – Account 60-89 days past the due date”. Skipping Account Status ’71 – Account 30-59 days past the due date”.
Is this correct?
Would the Payment History read “2000000000000000000000000”.
Is an adverse action required to send to a customer if the bank force closes the customer's checking account?
Do you provide a score, contained in a Chex Systems report, in an adverse
action notice for deposit accounts?
I'm working on our deposit audit and am confused by the definition of a
credit score. Section 615 of FCRA refers you to 609 (f)(2)(A) for this
(A) CREDIT SCORE.--The term "credit score"--
(i) means a numerical value or a categorization derived from a statistical
tool or modeling system used by a person who makes or arranges a loan to
predict the likelihood of certain credit behaviors, including default (and
the numerical value or the categorization derived from such analysis may also
be referred to as a "risk predictor" or "risk score"); and
(ii) does not include--
(I) any mortgage score or rating of an automated underwriting system that
considers one or more factors in addition to credit information, including
the loan to value ratio, the amount of down payment, or the financial assets
of a consumer; or
(II) any other elements of the underwriting process or underwriting
FCRA, Credit Score, Credit report
The Credit Reporting Resource Guide (CRRG) suggests that a partial charge-off be listed as a separate account with a new account number when the customer is liable for the partial charge-off amount. From an operational standpoint how would the payments be applied to the loan/loans and what is a good practice to ensure we collect all payments on both loans and not advise the consumer that the loan is paid off?
Example: On a $50,000 original note (Ln#123) amount. We charged off $10,000, leaving 40,000 still owed. The customer is current on his payments on the remaining $40,000.
According to Metro 2, they want us to lower Ln #123 to $40,000 and report a new loan #456 as a $10,000 charge-off.
How do you ensure that you don’t release the collateral until both loans are paid off?
Is there another way to report partial charge-off?
Will examiners be looking for detailed procedures on how we evaluate high flood deductibles?
What has happened to flood penalties in 2017?
If a written direct dispute relating to credit reporting is received there are clear procedures that must be followed. What about oral disputes? If an oral dispute is received must the financial institutions promptly update its credit reporting to reflect that the account is disputed? If so, would it have to be listed as disputed even if the financial institution does not agree with the dispute?