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#2257494 - 08/02/21 02:12 PM Prescreening
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,416
Bloomington, IN
I haven't dealt with prescreening in nearly 20 years so I need a little refresher.

Marketing is wanting to obtain a list of our bank's customers that have a mortgage that is not with our bank and solicit those with a credit score >= XXX to apply to refinance their mortgage with us.

1. From what I am reading because the solicitation is based on a credit score this would in essence be a pre screen; therefore a firm offer of credit would have to be offered otherwise we could not use the report for marketing purposes.

2. The information is being obtained from Savvy Money and from what I can determine they meet the definition of a reseller.

A. We cannot do the mailing based on credit score because of the pre screen's "firm offer" requirement.

B. If we only obtain the list based on them being our customer without a mortgage with our bank then we could solicit all those identified customers to apply for refinancing with us and not be out of bounds with the pre-screen rules (not based on any credit factor). An opt-out for future mailings will be included in the mailing.

Am I on track with my thinking? Thanks.
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The opinions expressed are mine and they are not to be taken as legal advice.

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Marketing
#2257495 - 08/02/21 02:39 PM Re: Prescreening Dan Persfull
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,216
Galveston, TX
If we only obtain the list based on them being our customer without a mortgage with our bank

So why do you need Savvy Money for to do that for you? Whether or not a person has a mortgage loan with another creditor would not be a credit report? Credit reporting criteria is more than just a credit score.
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#2257519 - 08/02/21 06:04 PM Re: Prescreening Dan Persfull
Inspector Offline
Gold Star
Joined: Apr 2016
Posts: 254
If you are getting the customer's mortgage holding status from the credit report information this would still be a prescreen and you would still need to make a firm offer of credit. Are you going to be able to make a firm offer just based on the fact that the customer has a mortgage with another lender? Seems like it could be a stretch.
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Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

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#2257529 - 08/02/21 07:12 PM Re: Prescreening Dan Persfull
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,416
Bloomington, IN
I've already informed them they will need to compile the list of customers without a bank mortgage from our core system.
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The opinions expressed are mine and they are not to be taken as legal advice.

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