Our RE dept. is setting up a Mortgagebot product whereby the loan officers will take the application verbally and load it onto the system as the customer gives him/her the information. Mortgagebot then will order the credit report through CredStar. Mortgagebot can print out/produce all of the disclosures for the loan officer to print, but apparently not the credit score disclosure. One of the options is for us to pay CredStar a fee to mail the disclosure out to the applicants. Management has decided that it it is more effecient and cost effective to take this automated option of having CredStar send the disclosure.
So, my question is what do you think we need to obtain as our "proof" that these go out since as the lender, we are still responsible for compliance with FCRA/FACTA? Will the contract and monthly invoice from CredStar be sufficient?
The opinions expressed are mine and do not necessarily reflect those of my employer