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#1624808 - 11/04/11 08:15 PM denials for credit score
aliasg Offline
100 Club
Joined: Jul 2007
Posts: 148
MD
Our company wants to deny loans for credit scores that fall below a minimum score requirement without going through underwriting or a fair lending second review. Is this a problem?

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Lending Compliance
#1624827 - 11/04/11 08:29 PM Re: denials for credit score aliasg
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,951
Bloomington, IN
Depends how you are arriving at that number.

If you are just choosing a number out of the air, problem.

If you have data relating to your loan portfolio that it has experienced a higher degree of delinquencies or losses on borrowers with scores of X or below, no problem. You will however at least every 18 months (I think it is) have to re-validate your data.
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The opinions expressed are mine and they are not to be taken as legal advice.

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