We have a holding company and affiliates. Our centralized underwriting group is housed at the holding company. The affiliates send the loan applications to our holding company underwriting group. The credit report is automatically pulled when the affiliate routes the loan to the underwriting group. Do you consider this to be sharing of the credit report? The affiliates can access the borrowers credit report. If so, does this require the opt-out?

The opt out for affiliate sharing is for situations where the affiliate will use the information to market products. Performing services on behalf of an affiliate is one of the exceptions to the affiliate marketing opt out requirements.