In addition, a trade association asked the Bureau to clarify the reporting responsibilities when a credit union contracts a credit union service organization (CUSO) to perform loan origination services.
Accordingly, if a credit union makes a credit decision prior to closing or account opening, then the credit union reports that decision. In addition, comment 4(a)–3.v addresses situations when a financial institution (in this case the CUSO) makes a credit decision using the underwriting criteria of a third party (in this case the credit union). In that case, if the CUSO makes a credit decision without the credit union’s review before closing, the CUSO reports the credit decision. However, if the CUSO approves the application acting as the credit union’s agent under State law, comment 4(a)–4 clarifies that the credit union is required to report the actions taken through its agent.
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