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#1527129 - 03/25/11 04:16 PM New Credit Report for Each Loan Request
Compliance Lover Offline
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Joined: Aug 2008
Posts: 555
So is everyone pulling a new credit report in order to get the credit score notice on each loan request even if there is a current one on file? We can go back 90 days and pull a new notice for that previous report but my understanding is it isn't technically permissible under the FCRA, that a new report should be pulled. Is that correct?

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#1527212 - 03/25/11 05:55 PM Re: New Credit Report for Each Loan Request Compliance Lover
RebekahL CRCM Offline
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RebekahL CRCM
Joined: Feb 2003
Posts: 874
Big Sky Country
We are only pulling new reports if the prior report is older than 90 days. If it is within 90 days, we are simply giving another copy of that credit score disclosure. This procedure is based on the thought that not a tremendous amount of information can change in 90 days, and the fact that our system for pulling reports has always asked us if we just want to re-print the "current" report if it is within 90 days.

I'm not certain that it is impermissable under the FCRA. Where in the FCRA are you getting that impression?
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#1527274 - 03/25/11 07:05 PM Re: New Credit Report for Each Loan Request RebekahL CRCM
RaesPlace Offline
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Joined: Mar 2011
Posts: 230
I am curious to know as well. The credit reporting agency that we use sends our notices for us, so another is not being given when we use an existing bureau for a new application.

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#1527305 - 03/25/11 07:31 PM Re: New Credit Report for Each Loan Request RaesPlace
Compliance Lover Offline
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Posts: 555
I believe I got that from an old post on here or else at a seminar. I did find these answers from posts at the end of last year:
FCRA has always been interpreted to mean that a creditor should obtain a new report for each transaction. Risk Based Pricing did not change or add anything to that rule.
You can't use a credit report already on file for a new request.
The answer you should be finding regarding the re-use of an older credit report is that you don't have a permissible purpose for using that CR on a new request. You should be pulling a new credit report, thus solving your problem all together.

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#1527312 - 03/25/11 07:38 PM Re: New Credit Report for Each Loan Request Compliance Lover
Compliance Lover Offline
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Posts: 555
I would prefer to use an existing report (within the past 90 days) if that is "ok".

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#1527478 - 03/28/11 12:51 PM Re: New Credit Report for Each Loan Request Compliance Lover
RaesPlace Offline
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Joined: Mar 2011
Posts: 230
The only times we would use an exisitng report is in a situation where a borrower would also qualify for a HELOC in addition to their first mortgage, and we submit that application the same day or within a few days of the first mortgage application.

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