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#2245962 - 11/30/20 08:07 PM Credit Report ran before FCRA notice
totallyconfused Offline
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Joined: Jul 2016
Posts: 104
The application for a Mortgage was taken over the phone on 9/1/2020. The credit report was ran on 9/1/2020. But the customer didn't come in and sign the application and FCRA notice until 9/3/2020. The FCRA notice has a date at the top of 9/1/2020 but the customer dated for 9/3/2020.

Is there an issue with this?

My concern is we don't have anything from the customer stating that it was okay to run the credit report that is dated by them for the date of the credit report.

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Lending Compliance
#2245963 - 11/30/20 08:09 PM Re: Credit Report ran before FCRA notice totallyconfused
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
I am not sure what FCRA notice you are referring too, but you had a permissible purpose to pull credit the minute the customer applied over the phone.
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#2245984 - 12/01/20 01:36 AM Re: Credit Report ran before FCRA notice totallyconfused
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
You say "My concern is we don't have anything from the customer stating that it was okay to run the credit report that is dated by them for the date of the credit report."
Ask yourself: How would you have the SSN to pull their credit report unless they gave it to you? if they gave it to you, they most likely were applying for a loan.

It sounds like an internal policy requirement. As Randy stated, there is no regulatory requirement to have the customer sign anything before pulling their credit report. You simply need a permissible purpose.
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David Dickinson
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