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 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”.
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?
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?
We have indirect dealers that will send contracts to us to buy. In the packet, we have them include proof that they provided a credit score disclosure to their applicant. Can you tell where in Regulation V this shows as a requirement for this type of verification or validation.
Credit Reporting: If we change a credit reporting status from current or account paid to BK or charged off, do we need to send the B-1 or B-2 notice pursuant to Reg V or some other type of notice that we are reporting negative information to the credit bureaus?
I am wondering what part Regulation V plays in FCRA and FACTA? I have been asked to review this for my next test and would like a little more insight into it.