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#1687973 - 04/11/12 06:32 PM She pulled her own credit report...
Anonymous
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I've got a Sr. VP that has pulled credit on herself through our CRA vendor.

It was in conjunction with her own loan, therefore this could be taken as a permissible purpose. She's not the officer on her loan though, thank goodness.

I've researched the reg and I can't find where it's not allowable to pull your own credit report.

I've reviewed our Conflict of Interest/Business Ethics policy and it doesn't really state much in there either, other than the fact that all officers and employess should have integrity.

1. How do I address this with her? We do not allow other employees to pull their own credit reports.
2. She's my boss.
3. Any verbiage from the Reg would be helpful.
Thanks!
Anon-E-Mouse.

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#1687979 - 04/11/12 06:41 PM Re: She pulled her own credit report... Anonymous
manimal Offline
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Check the language in the agreement with your CRA vendor too.

ETA: I would also check internal policy and procedures. It may be in your Loan Policy or in other procedures for pulling credit reports.
Last edited by manimal; 04/11/12 07:07 PM.
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#1688017 - 04/11/12 07:42 PM Re: She pulled her own credit report... Anonymous
BurntSienna Offline
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I think this was wholly inappropriate, all the way around.

If the credit report was pulled for the purpose of the loan, then the person handling the loan (not her!) should have pulled it. If the credit report was pulled for her own personal use (seems more likely to me that she wanted it and made herself a copy) then she should have ordered her own free annual report or paid for it herself, on her own time, from home, and not through your credit bureau on the bank's dime.

In terms of addressing this with her, if she is your boss, I would most likely not put myself in that position. I'd let someone else higher up the food chain deal with this situation. But I would first look for anything supporting this position in your bank policies about employees not being allowed to perform any sort of work/ maintenance/ processing on their own accounts. We have such statements in our bank's policies.
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#1688025 - 04/11/12 07:49 PM Re: She pulled her own credit report... Anonymous
Matt_B Offline
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Agreed with the above. I don't think you'll find anything in a reg on this, this is going to be internal policy.

But definitely bad practice and would be a big violation of our policies for sure. She is performing work on her own loan file, certainly not okay.

If you don't allow other employees to pull their credit, where does it say so? That's your backing. If it's in writing, I doubt is says it's against policy unless below X level on the org chart.
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#1688135 - 04/11/12 11:55 PM Re: She pulled her own credit report... Anonymous
rlcarey Offline
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Galveston, TX
Big, big conflict of interest in my book.
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#1688160 - 04/12/12 12:46 PM Re: She pulled her own credit report... Anonymous
DeeQ Offline
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Big conflict, big write up on a FCRA vio, too.
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#1688161 - 04/12/12 12:47 PM Re: She pulled her own credit report... Anonymous
DeeQ Offline
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Matt, I am referring to the 'valid reasons to pull credit", this doesn't fall under any valid category...
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#1688778 - 04/13/12 07:05 PM Re: She pulled her own credit report... Anonymous
Happy Birthday Beagles22 Offline
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I can assure you, this is in our contract with our credit vendor. I would start there first. It is now in our 'credit report' paperwork that I make all employees sign before they are given access to the system too (along with a whole bunch of other don't items).
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#1688857 - 04/13/12 09:28 PM Re: She pulled her own credit report... Anonymous
West Coast Comp Offline
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Deek,
Iím confused and need help (OK I need a lot of help, but that's another issue).

The bank is pulling credit as it intends to use the information in connection with a credit transaction involving the consumer on whom the information is to be furnished and involving the extension of credit to.

How is this not a valid reason to pull credit? What am I missing? Obviously she shouldn't have pulled credit herself, but she was acting on behalf of the bank which has a loan request. I don't think the fact that the loan was her own loan would change the fact that there did exist a valid business reason for pulling credit, does it?

Thanks for your help in understanding!
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#1688883 - 04/13/12 10:22 PM Re: She pulled her own credit report... Anonymous
rlcarey Offline
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Galveston, TX
I would be looking to the Bank's Code of Conduct/Ethics. It should say that no employee shall be involved in any personal/family transaction in any way. If it doesn't, it should.
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#1688893 - 04/14/12 02:45 AM Re: She pulled her own credit report... Anonymous
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Also, unless this was a credit report that is directly pulled into an origination system (which I doubt from the description) the employee pulling their own report essentially "taints" the report. It has passed through their hands and the bank now does not know if it has been altered. It is like a customer giving you the appraisal. It is no longer arms length and there's a risk it could have been altered.

Order a new credit report and change policy so that this is not allowed. Even if the new report is the same, you have removed the question mark hanging over the one the bank now has.
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#1688983 - 04/16/12 02:24 PM Re: She pulled her own credit report... Beagles22
HRH Okie Banker Offline
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Oklahoma
Originally Posted By: Beagle Queen
I can assure you, this is in our contract with our credit vendor. I would start there first. It is now in our 'credit report' paperwork that I make all employees sign before they are given access to the system too (along with a whole bunch of other don't items).


I also have some "Credit Report Procedures" that are required to be signed before I assign a Login I.D. to employees. We keep the signed form in their H/R file. I'd be glad to share if anyone wants to p.m. me.
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#1689354 - 04/17/12 02:36 PM Re: She pulled her own credit report... Anonymous
Andy_Z Offline
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The employee pulled their own credit report with a permissible reason. The bank is square with the FCRA and the vendor.

The issue is, could someone else have pulled that for the employee? I'm betting yes. Does the bank have an ethics/code of conduct policy that should prohibit an employee from doing any transaction for themselves, if it doesn't it should. It is an internal issue and perhaps one that needs to added to the training schedule. Assuming it is prohibited in the ethics policy, a counseling is in order, and move on.
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