I just want to make sure we got all the Regulation B changes:
1. Must provide appraisel notice in form customer can keep. (section 202.4(d))
2. Must document if applicants intentd to apply for joint credit. (section 202.7(d)(1))
3. Need to disclose to guarantor of loan that if adverse action is taken due to them the applicant will receive the denial notice with this information about the guarantor. (not sure where this is stated in the reg...can someone point it out)

Is there anything else we need to change?
Is there any article out there outlining these other than reading the 136 page revised act?

-New Government Monitoring Race & Ethnicity Codes
-Can't evaluate married and unmarried applicants differently (i.e. if you combine income of married applicants, you must also combine income of unmarried applicants)

Perhaps this should be a separate post, as I'm not really going to answer "anons" questions. I do have one of my own. New reg b requires that if we reject a loan for reasons associated with the co-applicant, co-maker or guarantor, that we must send that information in the AAN to the applicant. Don't we still have a requirement under FCRA to also send one to the co-app, co-maker or guarantor if information from a credit bureau was used in the decision? Any chance someone could comment on this? I'm still puzzled. Thanks

Help, I think this may have gotten by me---

Quote:

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1. Must provide appraisel notice in form customer can keep. (section 202.4(d))

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Previously, we operated under the option where we did not have to disclose because it is our policy to always provide the applicant with a copy of every appraisal. Is this option still available?

Where this comes from is:

Sec. 202.4 General rules.

(d) Form of disclosures. A creditor that provides in writing any disclosures or information required by this regulation must provide the disclosures in a clear and conspicuous manner and, except for the disclosures required by §§ 202.5 and 202.13, in a form the applicant may retain.

However, based on the following it is my opinion the option is still available.

Sec. 202.14 Rules on providing appraisal reports.

(a) Providing appraisals. A creditor shall provide a copy of an appraisal report used in connection with an application for credit that is to be secured by a lien on a dwelling. A creditor shall comply with either paragraph (a)(1) or (a)(2) of this section.
(1) Routine delivery . A creditor may routinely provide a copy of an appraisal report to an applicant (whether credit is granted or denied or the application is withdrawn).
(2) Upon request. A creditor that does not routinely provide appraisal reports shall provide a copy upon an applicant’s written request.

Thanks Dan. One down, 99 to go.