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#274431 - 11/12/04 06:23 PM Credit Score Disclosure - fees
Scooter Offline
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Scooter
Joined: Sep 2002
Posts: 216
Michigan
Our credit bureau rep. just informed us today that they can provide us with a one-page credit score disclosure - for $1.00 per credit report.

I doubt many can do it cheaper on their own. Does anyone see a problem with increasing our fee for the added cost? (Another option being provided is the credit bureau sending the disclosure for $2.50.)

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#274432 - 11/12/04 06:36 PM Re: Credit Score Disclosure - fees
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
You can increase the fee to cover the cost. However, remember this is a required disclosure and not a credit report. The additional fee will be a finance charge.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#274433 - 11/12/04 06:46 PM Re: Credit Score Disclosure - fees
Scooter Offline
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Scooter
Joined: Sep 2002
Posts: 216
Michigan
Glad I asked; I may have overlooked that in the rush of things.

(Just like life of loan on flood.)

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#274434 - 11/18/04 04:39 PM Re: Credit Score Disclosure - fees
rowdy Offline
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Joined: May 2004
Posts: 28
Home of the Buckeyes!
Is this a Pre-paid finance charge and part of the APR?
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#274435 - 11/18/04 04:44 PM Re: Credit Score Disclosure - fees
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
I will be part of the APR.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#274436 - 11/18/04 05:03 PM Re: Credit Score Disclosure - fees
Jim Offline
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Joined: May 2004
Posts: 127
New York State
We have been advised by CBC (Trans Union) that it is part of the credit report and not something to add to the APR.

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#274437 - 11/18/04 05:15 PM Re: Credit Score Disclosure - fees
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
Quote:

We have been advised by CBC (Trans Union) that it is part of the credit report and not something to add to the APR.




The original post asked about a fee that will be charged for the CB to mail the disclosure. That would be a finance charge if passed to the borrower.

I have to disagree with CBC in principal. Although the disclosure may be part of the credit report, it has nothing to do with establishing, or reporting the credit history of the applicant; and it is not used to determine eligibility for credit. It is a required disclosure.

I think if there is an additional charge for providing this disclosure with the credit report, that additional charge would be a finance charge if passed to the borrower.

Other opinions?
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#274438 - 11/18/04 05:15 PM Re: Credit Score Disclosure - fees
rowdy Offline
Junior Member
Joined: May 2004
Posts: 28
Home of the Buckeyes!
I don't think I'd rely on the Credit Bureau to interpret Reg Z. There's experts out there that still get confused on that stuff!
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#274439 - 11/18/04 05:46 PM Re: Credit Score Disclosure - fees
pjs Offline
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pjs
Joined: Aug 2004
Posts: 10,321
oHiO
I agree that it would be a finance charge if passed to the borrower-

I also agree on what does the credit bureau people know about the regs. But that's my opinion.

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#274440 - 11/18/04 06:19 PM Re: Credit Score Disclosure - fees
waldensouth Offline
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waldensouth
Joined: Nov 2001
Posts: 7,984
FINALLY ABOVE the gnat line
How will you comply if you have a recent credit bureau report in file and don't order a new one for a new application? Will you just keep a copy and reuse it?
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#274441 - 11/18/04 06:21 PM Re: Credit Score Disclosure - fees
Jim Offline
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Joined: May 2004
Posts: 127
New York State
Thanks for your input. I see where you are coming from and agree. It certainly won't hurt to call the $2.50 a Prepaid Finanace Charge.

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#274442 - 10/12/05 03:53 PM Re: Credit Score Disclosure - fees
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
Am I reading the post and thread correctly? Some of you are charging mortgage loan customers to provide the notice and disclose the scores, as per FACT Act section 212.

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#274443 - 06/12/06 05:46 PM Re: Credit Score Disclosure - fees
Sara Jane Offline
Junior Member
Joined: Dec 2005
Posts: 26
Can someone give me the section/location where it indicates this fee can be passed onto the consumer.

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#274444 - 06/13/06 04:02 AM Re: Credit Score Disclosure - fees
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
You can pass any actual charge on to the consumer that you want to. You will not find a section/location that says you can - nor will you find one that says you can't.
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