So we have the following situation:

Applicant applies for a 30 year mortgage loan. For whatever reason the applicant or property does not qualify and is denied by our investors. However the applicant would qualify for an in-house loan and want to proceed with that option.

We have been denying the first credit request and starting a new application for the in-house loan just to keep the loan file clean. My question is: do we need to pull a new credit report(and give new credit score disclosures) or can we re-use the original credit report?

Normally these situations happen within 30 days of each other and our credit bureau company does not care if we reuse credit reports.

Any help would be appreciated!

It depends on your loan policy. Ours allows us to reuse credit reports if they are no more than 90 days old. Don't forget to give the credit score disclosure/risk based pricing notice/notice to home loan applicant again though.

ADN,
I'm researching this as well, so admittedly, I'm not an expert on this topic, but I came across this thread you may want to read. It references a 1999 Advisory Opinion from the FTC.

Use of Existing Credit Report on File

It depends on your loan policy. Ours allows us to reuse credit reports if they are no more than 90 days old.

When you use these reports how are you satisfying ATR and/or QM requirments? A 90 day old credit report does not give you current obligations.

Well Dan, that post was a year ago. Since then, we have changed our policy to always require a new credit report for loans falling under ATR/QM rules. I understand we were late doing so, but we caught it and changed it.

Thanks!

I just saw Oct and didn't pay any attention to the year.....