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#1576138 - 07/11/11 04:01 PM AAN and RBP Notices
Lilly1234 Offline
Member
Joined: Dec 2010
Posts: 50
How is everyone handling sending these to consumers?

If you have to send to the prime and the joint, do you mail in seperate envelopes? Email in seperate emails? Same envelope if same address? etc...

How will this work for everyone else?

Thanks in advance.

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Lending Compliance
#1576159 - 07/11/11 04:23 PM Re: AAN and RBP Notices Lilly1234
ComplianceGrl15 Offline
Gold Star
Joined: Apr 2011
Posts: 257
West Virginia
The ABA Staff Analysis answered this:

http://www.aba.com/NR/rdonlyres/5F062DC6...uleJuly2011.pdf

4. Should the creditor provide the credit score of one applicant to another applicant, co-signer, or guarantor?
No. As proposed, while lenders may use the credit score of a guarantor or co-signer in making a decision, they should not provide the credit score of one person (e.g., the guarantor) to another (e.g., the applicant). Thus, even if the guarantor’s score was a factor in the decision, the applicant should not receive the guarantor’s score. (The regulation does not require that guarantors receive risk-based pricing notices).

5. If the applicant and any co-applicant reside at the same address, may the lender provide both credit scores in the same notice?
No. Whether the consumers have the same address or not, the lender must provide a separate notice to each consumer if a notice includes a credit score. Each separate notice that contains a credit score must contain only the credit score of the consumer to whom the notice is provided and not the credit score of the other consumer. The reason is privacy. If the notice does not include a credit score, separate envelopes are not necessary for co-applicants residing at the same address.

6. May the separate notices of joint applicants be inserted into a single envelope?
There is nothing in the final rule that prohibits a lender from inserting notices to each applicant into separate envelopes and then inserting those envelopes into a single envelope addressed to one address. The “insert” envelopes containing the notices should be addressed to the appropriate recipient.

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