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#2246543 - 12/15/20 03:57 PM Length of time customer's auth is good for
dutchbltz Offline
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Joined: Oct 2015
Posts: 207
Is there any regulatory guidance surrounding how long a customers' authorization for us to pull a credit report is good for? I know that we can pull as needed for annual reviews of commercial credit... but I'm specifically thinking about the authorization for initiating a credit request.

I'm thinking that given Reg B requires a credit decision within 30 days of a completed credit application, that a credit report for the initiation of a credit request should almost never be more than 30 days after the credit was authorized. But I'm not aware of any specific guidance on this and am wondering if any exists.

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#2246544 - 12/15/20 04:24 PM Re: Length of time customer's auth is good for dutchbltz
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
I am not really sure what this means: I know that we can pull as needed for annual reviews of commercial credit

But if you have an active application for credit - you have a permissible purpose. For most lenders, it is the first thing they do - otherwise any other action may be a total waste of time.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2246552 - 12/15/20 06:44 PM Re: Length of time customer's auth is good for rlcarey
dutchbltz Offline
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Joined: Oct 2015
Posts: 207
Correct - most of the time it would be done promptly. But is there any restriction as to how long we could do it for in conjunction with a request? Like how long that authorization COULD be valid for when in conjunction with a credit request?

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#2246564 - 12/15/20 09:42 PM Re: Length of time customer's auth is good for dutchbltz
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
As long as the application remains active, I would think. Permissible purpose involves a lender that "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". There is no expiration.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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