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#2284437 - 05/11/23 04:17 PM TRID credit application
Anonymous
Unregistered

When you have someone who just needs to get credit qualified for a TRID mortgage loan, can you collect for the credit report before you will run an application?

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#2284438 - 05/11/23 04:46 PM Re: TRID credit application Anonymous
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Official Interpretation
19(e)(2)(i)(B) Exception to fee restriction.
1. Requirements. A creditor or other person may impose a fee before the consumer receives the required disclosures if the fee is for purchasing a credit report on the consumer. The fee also must be bona fide and reasonable in amount. For example, a creditor or other person may collect a fee for obtaining a credit report if it is in the creditor's or other person's ordinary course of business to obtain a credit report. If the criteria in § 1026.19(e)(2)(i)(B) are met, the creditor or other person must accurately describe or refer to this fee, for example, as a “credit report fee.”
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#2284774 - 05/19/23 11:58 PM Re: TRID credit application Anonymous
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
Yes, but you need their written authorization to do so as technically, you don't have an application for credit yet.
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#2284775 - 05/19/23 11:59 PM Re: TRID credit application Anonymous
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
I should have said you don't have a permissible purpose yet (no application).
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#2284776 - 05/20/23 02:31 AM Re: TRID credit application Anonymous
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
If you have a pre-approval program, it's not an issue, you have all the information but the property.
Prequal programs the lender usually states to the prospective applicant in general terms such as "credit score of at least 650, 3 lines open, in bureau 1 year, nothing past 30 days, etc."
Like TTC said, I don't believe you would have permissible purpose.
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#2284782 - 05/20/23 01:52 PM Re: TRID credit application Anonymous
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
It really all comes down to what this means "When you have someone who just needs to get credit qualified for a TRID mortgage loan". If they have an actual pre-qual program, then they have an application for credit and thus a permissible purpose.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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