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#2230339 - 02/05/20 09:03 PM AAN and "credit obligations"
TeamComply Offline
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Are collections/past due items such as medical, tv/phone, energy bills, etc. considered credit? As far as AAN reasons go can these be considered "credit obligations" (such as in "delinquent past or present credit obligations with others") since they are non-credit related transactions? Is anything listed within a bureau report considered a "credit obligation" for AAN purposes?

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#2230529 - 02/07/20 06:26 PM Re: AAN and "credit obligations" TeamComply
TeamComply Offline
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Thoughts or guidance on this?? Please and thanks!

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#2230538 - 02/07/20 06:43 PM Re: AAN and "credit obligations" TeamComply
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
When there are collections being reported in the consumer report and they are a factor in the denial we use the model language shown on the model forms in Appendix C of Reg. B.

Collection action or judgment
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2230566 - 02/07/20 08:55 PM Re: AAN and "credit obligations" Dan Persfull
TeamComply Offline
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Posts: 540
So a collection is a collection on the bureau, regardless of whether its for a cable bill or a car?

And would everything included on the credit bureau also be considered a "credit obligation"?

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#2230574 - 02/07/20 09:18 PM Re: AAN and "credit obligations" TeamComply
rlcarey Online
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rlcarey
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Posts: 83,227
Galveston, TX
I would not think so. If someone didn't loan them money, is it really a credit obligation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2230578 - 02/07/20 09:27 PM Re: AAN and "credit obligations" TeamComply
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
FCRA

Creditor. Generally in FCRA, the terms “credit” and “creditor” have the same meanings as in
section 702 of ECOA (15 U.S.C. 1691a).

1691a

(d)The term “credit” means the right granted by a creditor to a debtor to defer payment of debt or to incur debts and defer its payment or to purchase property or services and defer payment therefor.

(e)The term “creditor” means any person who regularly extends, renews, or continues credit; any person who regularly arranges for the extension, renewal, or continuation of credit; or any assignee of an original creditor who participates in the decision to extend, renew, or continue credit.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2230579 - 02/07/20 09:41 PM Re: AAN and "credit obligations" TeamComply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Thanks Dan. I see the light smile
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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