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#2195893 - 10/18/18 08:27 PM Debt to Income Reason for Denial
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
I think this has been hashed over before......probably by me!! But I would like to revisit....

In preparing an adverse action notice, where the sole reason for denial is the debt-to-income ratio, and the debt used to calculate the ratio is taken directly from the credit report, do you check the box (or whatever method) to disclose "Our credit decision was based in whole or in part on information obtained in a report from the consumer reporting agency listed below?"
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The more you sweat in training, the less you bleed in battle.......

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#2195896 - 10/18/18 08:35 PM Re: Debt to Income Reason for Denial swiggles
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Yes, absolutely. Then you go on to provide the principal reasons for denial.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#2196129 - 10/22/18 08:46 PM Re: Debt to Income Reason for Denial John Burnett
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
BUT......if there is nothing wrong with the score, meaning no derogatory credit that would cause a denial......I should NOT disclose the score information?....Especially since the sentence preceding the disclosure says "We also obtained your credit score and used it in making our credit decision." That would be extremely confusing to a person whose credit is lily white with a score of 800....since the score was not used in the decision.
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The more you sweat in training, the less you bleed in battle.......

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#2196188 - 10/23/18 03:16 PM Re: Debt to Income Reason for Denial swiggles
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
See my comment here .
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The opinions expressed are mine and they are not to be taken as legal advice.

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