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#2245830 - 11/24/20 06:49 PM Unable to unfreeze credit report
liventhedream Offline
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I have a customer who has tried several times to unfreeze their credit with TU and each time it has failed. He called and they sent him a copy of his report. Two questions:

Is anyone else having issues getting credit reports unfrozen.

Can the bank rely on that credit report the customer sent us from TU

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#2245839 - 11/24/20 07:44 PM Re: Unable to unfreeze credit report liventhedream
rlcarey Offline
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Galveston, TX
Makes as much sense or maybe even less sense than using an appraisal that the customer handed to you. Let's see - I am not that person so I can't really unlock that credit report - but I have a fake one in my pocket that you can use.
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#2245857 - 11/24/20 10:07 PM Re: Unable to unfreeze credit report liventhedream
dutchbltz Offline
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I had a client who we tried REPEATEDLY to unlock her credit report. Couldn't get it done; although she was sending me screenshots showing that it was unlocked. Truly I kind of thought maybe she didn't really want to apply for a mortgage and was just like, un-locking it and re-locking it? I kept trying, and then telling her to try unlocking it again and to call me back when it was unlocked. Eventually I stopped hearing from her. This was a couple months ago; maybe June or July?

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#2245863 - 11/25/20 02:01 AM Re: Unable to unfreeze credit report liventhedream
BrianC Online
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Illinois
It's like the cash advance attempt that is declined so the customer hands you their cell phone to talk to "their bank" to get a verbal authorization number to force through the transaction. Of course, you're actually talking to their accomplance sitting in your parking lot.

Don't let a sob story cause you to circumvent your processes.
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#2245871 - 11/25/20 02:49 PM Re: Unable to unfreeze credit report liventhedream
InFairness, CRCM Offline
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InFairness, CRCM
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USA
A member of my family had this problem with TU earlier this year. Their consumer portal said the account was unfrozen, but the bank still could not pull my report. Of course, TU is also the credit bureau that responded to a request for a copy of a credit report with a form letter saying no record existed - attached to a copy of the credit report.
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#2245983 - 11/30/20 11:16 PM Re: Unable to unfreeze credit report liventhedream
one deer Offline
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Joined: Aug 2004
Posts: 77
Any where but work
Personally Equifax is the bureau we had trouble getting a freeze removed. Someone applied for a home loan in my husbands name; put blocks on all three bureaus under both our names. Equifax was like the circle of doom when trying to unfreeze my husbands account, his account may still be frozen; he is locked out and cant get it to reset his password. Gotta love technology.

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#2248131 - 01/25/21 09:27 PM Re: Unable to unfreeze credit report liventhedream
liventhedream Offline
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Has anyone dealt with the situation where the customer can get two of the three credit reports unlocked? Just can't get the third to unlock. If you have what have you done?

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#2248134 - 01/25/21 10:05 PM Re: Unable to unfreeze credit report liventhedream
InFairness, CRCM Offline
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USA
What does your policy say you will do if an applicant doesn't have reports with all three bureaus?
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#2270934 - 05/26/22 05:04 PM Re: Unable to unfreeze credit report liventhedream
CRL Offline
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CRL
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When we have an applicant with a credit freeze and they don't tell us or unlock it prior to our pulling credit, is it ok to charge the borrower the additional costs to re-assess their report for the unfrozen bureaus? Just making sure not an issue for charging more to a borrower with frozen credit.

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#2270937 - 05/26/22 05:08 PM Re: Unable to unfreeze credit report liventhedream
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
You charge a fee to assess (review) the credit report?
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#2270940 - 05/26/22 06:25 PM Re: Unable to unfreeze credit report liventhedream
CRL Offline
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CRL
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We charge a credit report fee for all loan applicants, when we pull their credit. When a borrower has it frozen, the bureaus charge an additional fee to "re-access" the report. We pass along actual costs to the borrower, thus a borrower who has frozen their credit and not unfrozen it prior to authorizing us to pull it, will be charged more.

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#2270942 - 05/26/22 06:40 PM Re: Unable to unfreeze credit report liventhedream
raitchjay Offline
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OK
Your original post said "re-assess", not "re-access"....i think that's where the confusion lies.
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#2270951 - 05/26/22 07:23 PM Re: Unable to unfreeze credit report liventhedream
CRL Offline
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CRL
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OH! Thank you, yes, I meant re-access (or re-pull) their report after they unlock their credit. When we need to do this, is it ok to charge the applicant the higher fees we incurred? I would think so, but just wondering if this could be an issue.

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#2270952 - 05/26/22 07:32 PM Re: Unable to unfreeze credit report liventhedream
raitchjay Offline
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OK
If you're just talking about generally, i would think state law would be your guide on what fees you can and cannot charge to your customers (but i would think most states would allow such a fee to be passed on to the customer).
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#2270953 - 05/26/22 07:40 PM Re: Unable to unfreeze credit report liventhedream
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
IMO this would be a changed circumstance and you could pass along the additional credit report fee, however the credit report fee is a 0 tolerance item. In order to reset the tolerance you would have to provide the consumer a revised LE disclosing the additional fee within 3 business days of learning you are going to have to "re-access" the credit report at an additional cost due to the freeze. If you don't meet the 3 business days revision rule then you will have to eat the additional fee.
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#2270954 - 05/26/22 07:45 PM Re: Unable to unfreeze credit report liventhedream
CRL Offline
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CRL
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Thank you both. I agree, and was also worried about ECOA, charging different amounts for different applicants, based on whether or not they have frozen their credit (and obviously not unfrozen it before authorizing us to access it.)
Last edited by CRL; 05/26/22 07:46 PM.
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#2270957 - 05/26/22 08:17 PM Re: Unable to unfreeze credit report liventhedream
raitchjay Offline
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OK
I don't see an ECOA issue....you aren't charging more based on a prohibited basis.
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#2270967 - 05/26/22 11:00 PM Re: Unable to unfreeze credit report liventhedream
InFairness, CRCM Offline
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USA
Is FCRA one of the consumer protection laws that is part of the Consumer Credit Protection Act? Regulation B forbids discriminating because of exercise of rights under the Consumer Credit Protection Act.
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#2270973 - 05/27/22 11:11 AM Re: Unable to unfreeze credit report liventhedream
rlcarey Offline
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Galveston, TX
It is, but I do see this as discrimination if the person applies for credit when their report is frozen, and the lender has to pay twice to get the report once this is determined.
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#2270979 - 05/27/22 02:37 PM Re: Unable to unfreeze credit report liventhedream
InFairness, CRCM Offline
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InFairness, CRCM
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USA
Conceptually, it reminds me of the kerfluffle a few years back about pulling merged reports for married coapplicants and separate reports for unmarried coapplicants. Even though lenders were incurring additional expenses (in some cases), the regulators concluded this was discrimination on a prohibited basis.
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#2270983 - 05/27/22 03:29 PM Re: Unable to unfreeze credit report liventhedream
rlcarey Offline
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rlcarey
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Posts: 79,628
Galveston, TX
That is not a comparable action. This is totally on the applicant if they apply for a loan without releasing the freeze.
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#2270999 - 05/27/22 08:31 PM Re: Unable to unfreeze credit report liventhedream
Andy_Z Offline
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On the Net
As I've not been in a bank or reviewing credit report bills, what does one cost today as compared to redisclosing your TRID items and the risk of an error? I'd guess the re-disclosure should be automated, but a lot of bankers want to resist doing these in the first place, let alone re-doing them.
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#2272107 - 06/25/22 10:39 PM Re: Unable to unfreeze credit report liventhedream
Rocky P Online
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Florida
CRL, with all the fraud and credit freezes, if it is a common issue, it should be part of the LO's script to inform the applicant that it is necessary to release credit freezes before applying. A few years ago, the SC Department of Revenue was hacked and the state recommended anyone who filed, and especially paid taxes to freeze all 3 accounts. We have had no problems unfreezing them for a day with all 3 bureaus.
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