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#1624421 - 11/04/11 01:26 PM Prescreened List
terpsfan Online
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If a list is purchase of homeowners in the area would this be considered a prescreened list? Also I don't believe using homeownership would have a disparate impact or am I missing something?

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#1624899 - 11/05/11 01:58 AM Re: Prescreened List terpsfan
rlcarey Offline
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rlcarey
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Galveston, TX
Who are you purchasing the list from and what are you going to use it for?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1624966 - 11/07/11 02:02 PM Re: Prescreened List rlcarey
terpsfan Online
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We are purchasing it from a third party marketing firm to use to advertise home equity and refinance mortgage products.

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#1626456 - 11/09/11 04:49 PM Re: Prescreened List terpsfan
terpsfan Online
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I am just not sure if homeownership would be considered a factor of credit worthiness making this list a consumer report.

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#1626459 - 11/09/11 04:55 PM Re: Prescreened List terpsfan
rlcarey Offline
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rlcarey
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Galveston, TX
These are probably just generated from current real estate tax records:

Public record information. A communication consisting solely of public record information is not a "consumer report" unless that information is provided by a CRA, is used or expected to be used for the purposes identified in section 603(d), and bears on at least one of the seven characteristics listed in the definition.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1626503 - 11/09/11 05:22 PM Re: Prescreened List rlcarey
terpsfan Online
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I don't think this would be considered using it to determine credit eligibility but you would have to own a home to qualify to refinance or get a home equity loan. Would homeownership be considered a personal characteristics or mode of living making it bear one of the seven characteristics? I think this part of FCRA is very confusing.
Last edited by terpsfan; 11/09/11 05:26 PM.
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#1626546 - 11/09/11 05:55 PM Re: Prescreened List terpsfan
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
Are you getting this information from a CRA?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1627915 - 11/14/11 02:43 PM Re: Prescreened List rlcarey
terpsfan Online
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No but based on the definition below if what they are giving us is a consumer report they could become one.

The term "consumer reporting agency" means any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties, and which uses any means or facility of interstate commerce for the purpose of preparing or furnishing consumer reports.

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