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#1437018 - 08/31/10 05:49 PM Adverse Action Help
Anonymous
Unregistered

Applicant wants to borrow money and use a car as collateral. Credit is run and clean. Car, however, has little value and will not support loan. Loan is denied. Adverse Action shows Credit bureau information.

Would it be correct to show credit bureau information if that did not play a role in your decision?

I believe it should not show credit bureau information but rather the third party language from Section 615 of the FCRA, but then again, I am not sure because collateral value is not one of the critera - credit worthiness, credit standing, credit capacity, character, general rep, personal characteristics, or mode of living (unless you could put it under credit capacity or standing). If you don't use this language and you don't put the credit bureau info, would you have nothing for the FCRA information part?

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#1437243 - 08/31/10 09:41 PM Re: Adverse Action Help Anonymous
NotALawyer Offline
Gold Star
NotALawyer
Joined: Nov 2001
Posts: 455
Was the decline due to the car not haveing enough value? "Unacceptable colateral" would be the decline reason. The third-party rule would apply if information was received about the individual, not the colateral.

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#1437762 - 09/01/10 07:06 PM Re: Adverse Action Help NotALawyer
Anonymous
Unregistered

Thank you! That makes perfect sense ("about the individual not the collateral").

So, if you use the standard AAN form which has the FCRA information preprinted on it, do you just cross it out or leave it blank? I know the pushback here is going to be "but there is a credit report in the file and the examiners will nail us if there is anything negative in the report, even if that didn't play in our decision."

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