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#2243146 - 09/25/20 06:55 PM When can a Credit Report be Pulled
Lizz Offline
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Joined: Aug 2013
Posts: 128
Dunkirk NY
Are you allowed to pull a credit report without an authorized borrowers blanket or loan application ? I thought this was a REG B violation ?

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#2243147 - 09/25/20 07:02 PM Re: When can a Credit Report be Pulled Lizz
Lizz Offline
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Joined: Aug 2013
Posts: 128
Dunkirk NY
Maybe not REG B - but Fair Credit Reporting Act - But are you allowed to pull a consumer credit report with the intent to provide consumer credit to a borrower - even if there is no loan application or borrowers blanket signed by the borrower?

Last edited by HMDA GIRL; 09/25/20 07:03 PM.
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#2243148 - 09/25/20 07:14 PM Re: When can a Credit Report be Pulled Lizz
Norman Paperman Offline
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You need a business purpose for pulling the borrower's credit. Prudence would tell you to have some form of acknowledgement (loan application, authorization, PFS, etc.).

When you say "there is no loan application"- are you saying there is no paper application or the borrower has not initiated a request. If the latter, you have an issue.
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#2243150 - 09/25/20 07:30 PM Re: When can a Credit Report be Pulled Norman Paperman
Lizz Offline
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Joined: Aug 2013
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Dunkirk NY
We have nothing in the loan file signed by the borrower - this loan was withdrawn -However, there was no actual loan application - no sign borrower blanket - There were correspondence in the loan file between the borrower and MO - so I believe that there was an intent for a loan purpose. But is that enough - there is no actual proof.. or would the emails between the borrower and MO be enough?

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#2243153 - 09/25/20 08:01 PM Re: When can a Credit Report be Pulled Lizz
rlcarey Online
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rlcarey
Joined: Jul 2001
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Galveston, TX
The permissible purpose bar in the FCRA is rather low:

(3) To a person which it has reason to believe

(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;

If you have intent use the information is pretty broad. However, with that said, most banks require an actual credit application so that loan officers do not inadvertently or intentionally pre-screen customers. Like why did this customer suddenly withdraw after the report was pulled? Did the loan office actually communicate that a loan might not be approved, then you have a denial.
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