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#2117486 - 02/08/17 05:47 PM AAN - Information from an Outside Source
Mel in WA Online
Diamond Poster
Joined: Mar 2013
Posts: 1,170
We are converting to a new LOS and updating our AAN. The vendor is providing a sample AAN that matches the model notice in Regulation B, except for the verbiage below:

"Our credit decision was based in whole or in part on information obtained from an affiliate or from an outside source other than a consumer reporting agency. Under the Fair Credit Reporting Act, you have the right to make a written request, no later than 60 days after you receive this notice, for disclosure of the nature of this information."

This is on our current AAN, but rarely (maybe never) used. Most of the time, it's marked in error. Is it acceptable to leave it off?

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Fair Lending
#2117583 - 02/08/17 10:13 PM Re: AAN - Information from an Outside Source Mel in WA
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
It is rare to use this and I don't believe you need to have it on the form, unless it is applicable. IOW, you don't have to have all info that is possible and then mark boxes to indicate what is applicable. Some systems print "tailored" disclosures and only provide applicable sections. If this is not applicable to 99 out of 100 applicants, you can leave it off. But what are you going to do when you have that 1 that needs this disclosure?
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David Dickinson
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#2149031 - 10/06/17 03:37 PM Re: AAN - Information from an Outside Source Mel in WA
MScarn6942 Offline
Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
Just to check - is information the borrower provided considered an outside source? One gave us an appraisal she had done for her and a loan amount and the LTV is too high so it was denied. Is that considered an outside source?
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#2149039 - 10/06/17 04:02 PM Re: AAN - Information from an Outside Source Mel in WA
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,234
Galveston, TX
No - and since the appraisal was totally not acceptable for use by the bank, how can you make your judgement using it?
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