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#282479 - 12/01/04 05:20 PM Model Notice
kentuckygirl Offline
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Joined: Nov 2004
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Does anyone have a copy of the model notice that they are going to give the customer. I am a loan officer and our compliance dept is telling us that we are going to have the notice signed at closing. However, I have contacted Equifax and this can possibly print with the credit report.

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#282480 - 12/01/04 05:36 PM Re: Model Notice
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
I will assume you're asking about the Sec. 212 Credit Score disclosure since you said you talked to Equifax and they indicated it could be part of the credit report.

Here's a sample disclosure. You'll need to scroll up.

However, providing this at closing will not meet the delivery requirements under the ACT. The ACT requires it to be delivered as soon as reasonably practicable. The consensus seems to be that would be within 3-5 days after receiving the credit report.
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#282481 - 12/01/04 05:37 PM Re: Model Notice
someone else Offline
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someone else
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Ours prints out with the credit report.

BTW - I think it would be in your best interest to have the Notice sent up front with your initial disclosures as the Act states that it is to be sent as soon as is "reasonably practical." I do not think you could argue that closing was "reasonably practical."
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#282482 - 12/01/04 05:38 PM Re: Model Notice
someone else Offline
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someone else
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back to my roots
Darn it Dan - you beat me to it!
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#282483 - 12/01/04 05:45 PM Re: Model Notice
Truffle Royale Offline

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Hey someone else, have you checked the disclosure your cba is giving you? Does it have the notice included with it like mine does?

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#282484 - 12/01/04 05:45 PM Re: Model Notice
Queen Mum Offline
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Queen Mum
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OK
Our loan processing software has the form but it also prints out as the last page of the credit report also filled in.

What I'm wondering - do we need to have a place for the customers to sign acknowledging receipt?

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#282485 - 12/01/04 06:02 PM Re: Model Notice
someone else Offline
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someone else
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back to my roots
bjp - yeah, our notices are included. pretty cool, eh?
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#282486 - 12/01/04 06:12 PM Re: Model Notice
river girl Offline
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There are no requirements for any FACT Act disclosures to be signed or retained.

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#282487 - 12/01/04 06:13 PM Re: Model Notice
Queen Mum Offline
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Queen Mum
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OK
If we send this with the 3-day disclosures, we only need to send the one correct? I'm still confused on this. I read where some say that you need to provide a separate disclosure to each borrower in separate envelopes.

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#282488 - 12/01/04 06:21 PM Re: Model Notice
waldensouth Offline
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waldensouth
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FINALLY ABOVE the gnat line
Equifax told us they had no plans to offer the credit score disclosure with the report. Of course, that person also told us that the credit bureaus weren't going to tell the consumer anything about their score either.
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#282489 - 12/01/04 06:32 PM Re: Model Notice
Truffle Royale Offline

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I'm thinkin' the seperate disclosures in seperate envelopes will come into play when 615(h) is kicked into gear.

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#282490 - 12/01/04 06:46 PM Re: Model Notice
Terry Offline
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Terry
Joined: Sep 2001
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Midwest
In our case, Equifax is not providing anything other than the regular data they've always provided in the credit report. But the regional credit bureau through which we get the Equifax credit report is taking the data and formatting it into the credit score discloure for an additional fee.
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