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#1055293 - 10/01/08 03:44 PM FCRA notice on Adverse Action Notices
Poohie Offline
100 Club
Joined: Jan 2006
Posts: 200
USA
Here is the question:
If I pull a credit report and the credit looks okay and then I deny the loan for some reason other than what's on the credit report, do I need to provide the credit bureau information since I did use a credit report?

My research into the FTC Statements of Policy did not help me to answer this question. Perhaps you can...

Thank you

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Lending Compliance
#1055314 - 10/01/08 03:51 PM Re: FCRA notice on Adverse Action Notices Poohie
Always In Training Offline
Diamond Poster
Joined: Jul 2006
Posts: 1,115
Where the Green Grass Grows
We put it on every AAN we do, when we pull credit. May not be correct. But, then, I can't think of a time we've denied someone for a reason that wasn't on the credit report too.

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#1055364 - 10/01/08 04:07 PM Re: FCRA notice on Adverse Action Notices Always In Training
Ray_ Offline
Platinum Poster
Joined: Aug 2006
Posts: 879
Dallas, TX
If you pull credit on someone I feel they deserve the notice. As Always said, it may not be right, but you don't risk not providing the notice when you should have.

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#1055805 - 10/01/08 07:38 PM Re: FCRA notice on Adverse Action Notices Ray_
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
No, No, No. The FCRA disclosure is only to be provided when the credit report leads to the denial. Think about this. Poohie pulls my credit report. Everything is fine, but the bank denies for loan to value. I see the FCRA disclosure and go through the hassle to get a free copy of my credit report. I know that my credit is fine, but the disclosure says it led to the denial (READ IT!). I'm worried about ID Theft or incorrect reporting.

When I get my free copy, I see nothing wrong. Why?

Additionally, the CRA's must give out a FREE copy of the report. They have tried to straighten this out for years. I don't deserve a free copy and they shouldn't have to give me one.

The examiners in this part of the country site banks for over disclosure (appropriately so).
_________________________
David Dickinson
http://www.bankerscompliance.com

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