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#1629676 - 11/17/11 04:38 PM Credit Score Disclosure with every loan request
KathiB Offline
New Poster
KathiB
Joined: Feb 2011
Posts: 4
Texas
Recently we were told by Loan Operations that a CSD is only required when a credit report is pulled. If we do a second or third loan using this credit report, does a new CSD have to be given with each loan request?

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#1629700 - 11/17/11 05:01 PM Re: Credit Score Disclosure with every loan request KathiB
ktac MITCH Offline
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ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
Short answer is Yes.
The requirement is you give the notice to "Applicants", so when you have an existing customer(s) (say a loan 3 mo ago) who applies for another loan, you have to give the disclosure(s).

Now - if you are relying on a previous credit report (ie pulled for the prior loan) your disclosure would include that info, because that is the credit score that you are basing your current loan decision on. (So it would indicate the score and the date of the credit report from 3 mo ago)
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#1629714 - 11/17/11 05:13 PM Re: Credit Score Disclosure with every loan request ktac MITCH
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Of course that does not address the fact that you have no permissible purpose to use a credit report pulled for one credit transaction for subsequent lending transactions. smile
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1629788 - 11/17/11 06:18 PM Re: Credit Score Disclosure with every loan request rlcarey
KathiB Offline
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KathiB
Joined: Feb 2011
Posts: 4
Texas
Permissable purpose? Our loan policy says that credit reports can be a year old and to avoid "dinging" the customer's credit, we use the old credit reports. We're not supposed to? We always have them fill out a credit application which they sign and it gives us permission to pull credit, we just don't.

Please, more information!

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#1637496 - 12/09/11 05:43 PM Re: Credit Score Disclosure with every loan request KathiB
RaesPlace Offline
100 Club
Joined: Mar 2011
Posts: 230
@ RLC, if the file is documented that permission was received from the applicant to use CB dated xx/xx/xxxx, will that suffice?
Last edited by lmh0104; 12/09/11 05:43 PM.
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