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#1458158 - 10/21/10 07:40 PM FCRA Permissible Purpose for Credit Report
NeBanker Offline
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Joined: Jun 2008
Posts: 410
I am currently doing a FCRA audit and am working through the FCR Examination Procedures pertaining to permissible purpose for credit reports. The procedures say to compare the billing statement from the CRA to the banks records to enusre there was a permissible purpose for the credit report. Heres my problem our billing statement is not broken down to who we pulled the credit report on rather how many credit reports were pulled. How would one determine if the credit reports pulled were permissible?

Thanks

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#1458200 - 10/21/10 08:25 PM Re: FCRA Permissible Purpose for Credit Report NeBanker
BrendaC Offline
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Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Ask for a more detailed list. I know they exist because I performed this type of audit in the past and looked used a report that identified all aspects of the inquiry - who, what, when, and where.
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#1460751 - 10/28/10 03:59 PM Re: FCRA Permissible Purpose for Credit Report BrendaC
Allformyfamily Offline
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Allformyfamily
Joined: Jun 2010
Posts: 150
Our statement from our CRA does not do this either. We generally have our loan clerk go into the website and pull the detailed list of who the reports were pulled for and compare it to the billing statement.
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#1460828 - 10/28/10 05:10 PM Re: FCRA Permissible Purpose for Credit Report Allformyfamily
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Perhaps it was this type of list, attached to the billing, that I was given to review as part of the audit. Makes sense.
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Life without Jesus is like an unsharpened pencil - it has no point.

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#1461718 - 10/30/10 12:19 AM Re: FCRA Permissible Purpose for Credit Report BrendaC
Rocky P Offline
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Joined: Jun 2003
Posts: 7,650
Florida
CRA's each have their own way of billing. Equifax (small user), provides a detailed listing of reports pulled, and includes who pulled the report. On larger accounts, it may be possible to get the information in an excel file.

If Loan officers can pull credit bureaus from a laptop, you may want to include the step that reports are pulled during [normal business] / [reasonable] hours. Many (many) years ago, I was doing a similar audit and noted that one of the reports was pulled after midnight. After discussion, the LO admitted meeting someone at a lounge, and he got enough information to pull her credit report (from his laptop on his kitchen table on a Saturday night) to make sure she wasn't pulling to much baggage. It resulted in an immediate termination.

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