Just another question for those of you using the Exception notices rather than the Risk-Based Pricing Notices...are you going to pull a credit report with every application? Some interpret it to be that every consumer that applies will need to receive the exception notice, but others say that if you don't pull a report you don't have to give either one of the notices.
I am so confused at this point!!
We are only using exception notices on 1-4 fam RE loans.....but I'm pretty sure that if you don't pull a report/use a credit report on someone, then you don't have to give it. Say I submit a joint application with another person who is trying to build their credit. You pull my credit first and it is excellent. You determine that my credit info alone and the agg DTI is sufficient to underwrite the credit and make the loan, so you don't pull my joint applicant's credit at all. I think you would only have to give the notice/credit score disclosure to me.
Now, things like that don't happen very often, but if they did, I think you would be ok to only give it to the person you pulled credit on.