I think I'm just here to ramble and vent about Risk-Based Pricing.

We are going to use the exception notices. I was wondering if others were going to use the forms produced by their credit reporting agency or those produced by your platform system?

We use Equifax's Eport to order reports and I don't like the idea of having to go to another screen and choose/print the form. I think I'd rather go with our platform system. We can program that to ask a few more questions and force the form to produce. Way less room for error.

Maybe if I was in a more controlled centralized consumer lending atmosphere the forms produced by Equifax would be easier.

I'd appreciate comments from others about this.

We are using our platform, though be wary about thinking less room for error...they still have to type the reasons in and there will be errors when they have to type in what they read off the report. We set ours to prompt as much info as possible, but the score and reasons have to typed in and can't be prompted (ie drop down menu).

We were hoping to use the exception notice for 1-4 from our provider (a thrid party provider who compiles Equifax reports via Expert); however, when I saw their version of the form, I did not think it would be compliant. So until they change it (if they do at all), we are 100% in-house.

The Exception notice prints with the credit report automatically for us. We have decided to just use them rather than re-type the information already on them into the platform system and possibly have an error or leave something out.

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!!

You should be providing a new (exception) notice every time you use a credit report in connection with a credit application (consumer credit to an individual, that is). If you were currently relying on older credit reports, then you are reviewing credit reports in connection with a new application so therefore you should be pulling a new report so you can get a new exception notice with fresh information in it.

Also, several posts have been made stating that using an older bureau report on a new application is not allowed under the permissible purposes outlined in the FCRA.

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.

I'm going with the CRA, due to the fact that if we use our loan origination software then we've have to transacribe the info from the CRA into it, which takes more time and introduces a chance of error.

we are using our credit bureau.

QM - Which CRA do you use that the exception notice prints automatically? It looks like Equifax, through Eport, requires us to go into another screen to request the appropriate notice and print it.

We go through Kroll Factual Data.

I have also been told that there isn't anything that says that we can't. Does anyone know exactly where to find that in the Regulation so we know for sure?

Queen Mum.... when processing for Freddie (Loan Prospector) and Fannie (Desktop Underwriter) if a customer's initial is missing or an incorrect address or zip code is entered, these underwriting systems will generate a new credit report. The credit bureau we use will automatically send a notice on this reports as well so the consumer would be getting a duplicate notice; the first one we pulled for our loan application and one for Freddie or Fannie. Extra $$$$ Any thoughts on this?

Don't know that much about the Fannie and Freddie stuff. We had the option of having the credit bureau send out the CSN but in those cases where we do the loan the same day as applied for they wouldn't have received it before consummation.

Thank you and Happy New Year!