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#1672030 - 03/01/12 09:04 PM Prequalifications and GMI
RaesPlace Offline
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Joined: Mar 2011
Posts: 230
I started a new thread because the existing one was making my head spin and there were several different topics being discussed. I am curious if we are wrong to collect GMI information on our prequal applications?


Last edited by lmh0104; 03/01/12 09:06 PM.
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#1672037 - 03/01/12 09:18 PM Re: Prequalifications and GMI RaesPlace
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
I would collect the information under the requirements of Reg B 1002.13. If you note in the Commentary to 1002.2(f) it states the creditor has the latitude under the regulation to establish its own application process and to decide the type and amount of information it will require from credit applicants.

IMHO a pre-qualification application is a request for credit. It's just that certain regulations excludes them from their definition for disclosure, notification and/or reporting requirements.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1672042 - 03/01/12 09:21 PM Re: Prequalifications and GMI RaesPlace
RaesPlace Offline
100 Club
Joined: Mar 2011
Posts: 230
Thank you Dan. I agree.

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