I understand that you must report the FCRA info on adverse actions if you used information from a credit report to deny the loan, but does this include using the debt listed on the credit report as well? We did not deny based on the credit score (over 700) but did deny due to excessive obligations in relation to income.
We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.
How can we use existing software to track loan-to-value exceptions?
We have a savings account that was opened March of 1993 titled hypothetically: Mary Smith and John Smith Trustees for Tim Smith. Does anyone ever remember titling accounts this way for payable on death purpose?
Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?