Hi!

I read a few old threads were the issue of pulling credit was discussed. As you know, the "social security number to obtain a credit report" is one of the six pieces of information that make up an application.

If we receive all 6 pieces, but then the applicant calls to request that we hold off on pulling their credit report, do we still have a complete application?

For TRID - yes. Or you can just tell them you are considering the application officially withdrawn and to let you know when they are serious.

I understand a shopper not wanting every lending institution not pulling their credit. I would go on and look at it and if it appears to be a viable application, disclose and see if they move forward. If there is other info that would cause it to not work, I'd deny and move on.

How do you know what to disclose if you don't even know what their credit score might be or what their overall credit looks like? If you have fees that vary based on credit, you are going to lock yourself into something that you might not want to. Pulling credit is not a valid reason for a changed circumstance.

From a Reg. B standpoint though, would telling the applicant that we are considering their application withdrawn not be contrary to the "expressly withdrawn applications" commentary under 1002.9?

They call you up and say don't run my credit. That puts you dead in the water as a creditor. Not sure how much more of an express withdrawal you can get from the applicant.