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#2174268 - 04/19/18 03:51 PM Risk Based Pricing Notice & Reusing Credit Report
dhutson Offline
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Joined: Sep 2015
Posts: 30
If we pull a credit report for business purposes and do not provide the risk based pricing notice since it is not required, do we have to provide the risk based pricing notice if we reuse the same credit report for a consumer purpose loan?

https://www.bankersonline.com/regulations/12-1022-070
I'm guessing yes, but i'm uncertain.

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#2174270 - 04/19/18 04:01 PM Re: Risk Based Pricing Notice & Reusing Credit Report dhutson
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
The first question you have to ask is - what is my permissible purpose for reusing an existing consumer report on another loan transaction.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2174294 - 04/19/18 05:21 PM Re: Risk Based Pricing Notice & Reusing Credit Report rlcarey
dhutson Offline
Junior Member
Joined: Sep 2015
Posts: 30
The 2nd transaction has a loan application and it looks like the permissible purpose would be in connection with a credit transaction involving the same consumer as the first transaction only this time the purpose of the loan is consumer.

Sec 604 (a)(3)(A) intends to use the information in connection with a credit transaction involving the consumer on whom the information is to be furnished and involving the extension of credit to, or review or collection of an account of, the consumer

Also wondering if we reuse credit report pulled for a consumer purpose loan for a 2nd consumer purpose loan to the same borrower a month later, do we have to re-disclose the Risk Based Pricing Notice.

Not finding any language about reusing the same credit report. Any suggestions?

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#2174300 - 04/19/18 05:34 PM Re: Risk Based Pricing Notice & Reusing Credit Report dhutson
dhutson Offline
Junior Member
Joined: Sep 2015
Posts: 30
Found this discussion. https://www.bankersonline.com/forum/ubbthreads.php/topics/2074118/reusing-a-credit-report

Now I see why you asked about the permissible purpose.

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#2174335 - 04/19/18 06:36 PM Re: Risk Based Pricing Notice & Reusing Credit Report dhutson
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
dhutson - Welcome to BOL. Glad you found that previous thread - it is a good one.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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