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#1606070 - 09/20/11 05:40 PM Adverse Action Notices and Prequalifications
LMP Offline
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Joined: Sep 2011
Posts: 74
If a consumer does not prequalify for a loan due to credit score, are we required to provide an Adverse Action Notice and where is this stated in Reg B.

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Lending Compliance
#1606093 - 09/20/11 06:02 PM Re: Adverse Action Notices and Prequalifications LMP
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
Yes, you must provide the notice but you cannot deny based on credit score. Your denial must state the reasons pertaining to the factors that caused the score to be low.

As far as where it is found. You would need to read the definitions of "adverse action," "application," and "completed application" under 202.2. And then read the section about notifications at 202.9.

If the customer applied for pre-qualfications and you say "no," it's an adverse action event.
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The more you sweat in training, the less you bleed in battle.......

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#1606134 - 09/20/11 06:45 PM Re: Adverse Action Notices and Prequalifications swiggles
RR Joker Offline
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Posts: 20,656
The Swamp
agree
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1606140 - 09/20/11 06:50 PM Re: Adverse Action Notices and Prequalifications RR Joker
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
Thanks RR....I don't answer very frequently. But sometimes I do just to test myself to see if I'm right.....knowing that someone will jump in if I'm wrong. Concurrence sure does help!
_________________________
The more you sweat in training, the less you bleed in battle.......

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#1606154 - 09/20/11 07:03 PM Re: Adverse Action Notices and Prequalifications swiggles
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
grin
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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