A request from the borrower for an extension is a credit request, and sufficient for the creditor to pull a credit report. But if the creditor determines that it will not permit an extension, it now has a denial and a need for an adverse action notice. But you can't pull a report without a request for credit, whether it's a request to refinance, for an extension, or for another form of accommodation.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8