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#249137 - 09/25/04 12:38 AM prescreening 1st time
wavewatcher Offline
Diamond Poster
wavewatcher
Joined: May 2003
Posts: 2,053
Hawaii
This is my first experience with prescreened solicitations. Marketing dept wants to send out prescreened solicitations based on the following criteria:
SFD Owner-Occupants in our state
CLTV identified
FICO identified

Marketing will obtain list of Owner-Occupant homeowners on our state who meet the following criteria:

Owner-Occupant
Single Family Dwelling
Tax Assessed Value

List will be sent to credit reporting agency for prescreening to meet credit criteria.

3rd party will create preapproved offer letters and acceptance certificates for a HELOC based on the FICO score and calculated preapproved loan amount. Preapproval will be subject to proof of ownership, verification of employment and no substantial change to criteria used to select them for the preapproved offer. Recipients may apply for higher line amounts than their preapproved offer.

What should I be looking for in determining if compliance regs are satisfied? Thanks for the insights.

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Marketing
#249138 - 09/25/04 02:00 PM Re: prescreening 1st time
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,358
Galveston, TX
One thing is you have to actually make the mailing to everyone that comes back on the list. Are you really going to include the "whole" state? You may get a larger list back than you expect.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#249139 - 08/05/05 06:00 PM Re: prescreening 1st time
DebbieC Offline
Member
Joined: Jul 2001
Posts: 66
Owensboro, KY USA
I have a concern with our marketing area. We had always added "No birthday earlier than 19XX" to our prescreening criteria to eliminate anyone younger than 18 since they would not be able to sign a legal contract in our states. Now I find that the marketing area has been using criteria to narrow their focus by age group i.e. (between the age of 35 and 50). I am trying to tell them it is a violation of Reg B...our external marketing agency is telling me all "their banks" are requesting this type of criteria. Am I wrong...does this not violate Regulation B?

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#249140 - 08/05/05 06:40 PM Re: prescreening 1st time
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,358
Galveston, TX
The use of a prohibited basis in your pre-screening criteria is asking for trouble. For example, if you are offering a "promotional" rate or terms to only those people receiving the offer in the mail, you have a real issue.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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