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#2244022 - 10/14/20 05:08 PM ECOA-FCRA Adverse Action Confusion
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
At a recent seminar, the presenter stated information below. Have I been living under a rock? Has something changed? I have scoured the ECOA and FCRA and cannot find support for this.

This presenter states that in every scenario, Applicant A receives all ECOA reasons for denial. OK....I agree. Then he says that if Applicant B has bad credit, then Applicant B must receive only the reasons for denial that apply to applicant B....never heard of this.

Then, he said that if the bank bases the denial on information obtained from an outside source, such as an appraisal, not to forget to check the box which states that the bank made it's decision based on that "outside source" information. I thought that that particular statement was to be selected regarding information that bears upon the applicant's credit capacity.

Any comments are welcome. I'm worried we are doing this wrong. But if we abide by the above, I am worried that we WILL be doing it wrong.
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#2244024 - 10/14/20 05:24 PM Re: ECOA-FCRA Adverse Action Confusion swiggles
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
Wow - hope you didn't drop a lot of cash on this presentation. The presenter is the one under the rock and should really just stay there smile
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#2244035 - 10/14/20 06:53 PM Re: ECOA-FCRA Adverse Action Confusion rlcarey
Adam Witmer Offline
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I'm with Randy as this person seems to be out on their own. Did you ask for citations?
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2244038 - 10/14/20 07:12 PM Re: ECOA-FCRA Adverse Action Confusion swiggles
swiggles Offline
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swiggles
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Posts: 7,351
I shall.
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The more you sweat in training, the less you bleed in battle.......

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#2244106 - 10/15/20 05:18 PM Re: ECOA-FCRA Adverse Action Confusion swiggles
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
This presenter is a well-known compliance consultant, whose chart states to do it this way. No....It's not David. LOL
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The more you sweat in training, the less you bleed in battle.......

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#2244504 - 10/23/20 03:31 AM Re: ECOA-FCRA Adverse Action Confusion swiggles
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Thanks for clarifying that swiggles! smile
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http://www.bankerscompliance.com

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