If we request a foreign applicant to provide a foreign credit report as part of a prequalification request, then the applicant submits an application based on the results of the prequal, do we need to include the fee the applicant paid for the report on the LE as POC since we required it and used the report?

Thanks,

I guess I am more concerned with you even looking at a document like that which the applicant provides. What good is it? Do you let them do their own appraisal also?

But the answer to your question is yes.

We were not able to obtain it ourselves, apparently only the individual of the report can get one from a Mexican credit reporting agency. It has all the information like a U.S. credit report and we will evaluate it the same for underwriting purposes.

Would requesting it be a compliance issue?

Thank You.

Not a compliance issue, but a safety and soundness issue. Give me five minutes and a computer and I can give you a credit report with whatever you want on it.

Thank You.

Oh, and if this person is not a U.S. Resident, you don't even have to worry about how to disclosure it, as Regulation Z would not even cover the transaction:

Official Interpretation

1(c) Coverage

1. Foreign applicability. Regulation Z applies to all persons (including branches of foreign banks and sellers located in the United States) that extend consumer credit to residents (including resident aliens) of any state as defined in §1026.2. If an account is located in the United States and credit is extended to a U.S. resident, the transaction is subject to the regulation.

Is it required to pull a credit report if the foreigner has a tax id? And what to do if the foreigner doesn't have a tax id?

Pulling a credit report is a credit underwriting decision and nothing more.