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#1531458 - 04/05/11 03:06 PM Dealer Performance data and credit decisions
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 527
Midwest
Our Indirect auto underwriters are using dealer application volume, booking volume, portfolio performance and loan profitability to make a "more informed" credit decision or exception when evaluating new credit requests.

This seems completely wrong to me- those factors have no bearing on the applicant's creditworthiness, yet I can't find anything in Reg B that prohibits this. Reg B says that a creditor may consider any information obtained, so long as the information is not used to discriminate against an applicant on a prohibited basis. Am I missing something, or is this really ok to use??

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Lending Compliance
#1531794 - 04/05/11 09:15 PM Re: Dealer Performance data and credit decisions M&M
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 527
Midwest
Really hoping someone will chime in here. Reg B defines "pertinent element of creditworthiness" as follows: in relation to a judgmental system of evaluating applicants, means any information about applicants that a creditor obtains and considers and that has a demonstrable relationship to a determination of creditworthiness.

No where, though, does Reg B say that a creditor is required to use only these elements...

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