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#1682295 - 03/26/12 08:08 PM Credit Cards not on our books
Beagles22 Offline
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Joined: Jan 2004
Posts: 3,626
State of confusion
We just began outsourcing our credit cards. So we sold our existing portfolio, and now we give out applications and send them to another company that underwrites, approves/denies, and issues the credit cards in their name, not ours. Does anyone know if we have to retain copies of those applications? And if so for how long? This is new to me, I appreciate any help anyone can provide.
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Lending Compliance
#1682401 - 03/27/12 12:50 AM Re: Credit Cards not on our books Beagles22
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
You are just acting as a go between - I don't know of any retention requirements.
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#1683213 - 03/28/12 05:26 PM Re: Credit Cards not on our books Beagles22
Beagles22 Offline
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Joined: Jan 2004
Posts: 3,626
State of confusion
That is what I thought too Randy. Thanks so much for the answer.
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Going to church doesn't make you a christian any more that standing in your garage makes you a car.

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#1684636 - 04/02/12 02:08 PM Re: Credit Cards not on our books rlcarey
ynot Offline
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Joined: Sep 2011
Posts: 81
Florida
In this situation would the bank be required to give their privacy notice at the time the application is given to the customer?

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#1684651 - 04/02/12 02:28 PM Re: Credit Cards not on our books ynot
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
From the original post.

to another company that underwrites, approves/denies, and issues the credit cards in their name

The applicant is not the bank's customer.
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#1684662 - 04/02/12 02:35 PM Re: Credit Cards not on our books Dan Persfull
ynot Offline
Member
Joined: Sep 2011
Posts: 81
Florida
Thank you, just as we thought.

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