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#1909019 - 03/27/14 01:07 PM Adverse Action - Decision based on other reason
Anonymous
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Application received for home purchase. Credit pulled and after further investigation, it was discovered that property was a manufactured mobile home. Bank does not offer a mortgage product for this type of financing. On adverse action notice, we checked "Other" reason to explain this. But should we also check the box for "Our credit decision was based in whole or part on information obtained from an affiliate or from an outside source other than a consumer reporting agency"?

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#1909024 - 03/27/14 01:09 PM Re: Adverse Action - Decision based on other reason [Re: Anonymous]
rlcarey Online
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rlcarey
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Galveston, TX
What "outside" source was used?
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#1909025 - 03/27/14 01:10 PM Re: Adverse Action - Decision based on other reason [Re: Anonymous]
RR Joker Offline
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RR Joker
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The Swamp
So, type of collateral is insufficient. How did you find this out? If from an outside source, then yes...if it's because the customer told you, then no.

Fixed. Randy has had more coffee this morning than I have.
Last edited by RR Joker; 03/27/14 01:19 PM.
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#1909028 - 03/27/14 01:13 PM Re: Adverse Action - Decision based on other reason [Re: Anonymous]
rlcarey Online
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rlcarey
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Galveston, TX
What does collateral have to do with the consumer? FCRA disclosures are required when you get information about the consumer themselves. Otherwise, you would include it every time you ordered an appraisal that came in lower than expected. That has nothing to do with FCRA.
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#1909711 - 03/28/14 04:51 PM Re: Adverse Action - Decision based on other reason [Re: Anonymous]
Anonymous
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Do you think regulators might see an issue if we are checking the box that says the decision was based on an outside source other than a consumer reporting agency when it was really due to collateral value?

Thanks!

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#1909733 - 03/28/14 05:38 PM Re: Adverse Action - Decision based on other reason [Re: Anonymous]
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 73,292
Galveston, TX
Yes - it is not correct. So, normally when you do things that are not correct, the regulators have an issue with it.
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