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#289396 - 12/15/04 07:36 PM Timing of Credit Score Disclosure
Mel Offline
100 Club
Joined: Mar 2004
Posts: 100
From an operational standpoint, it's "reasonably practicable" to provide the Credit Score/Home Applicant disclosure at closing or with the adverse action notice. Could this be an issue because it may be several days after the credit report was obtained?

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#289397 - 12/15/04 07:53 PM Re: Timing of Credit Score Disclosure
Anonymous
Unregistered

A credit report is the first thing we do. Why not send it out with the Good Faith Estimate and other disclosures?

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#289398 - 12/15/04 07:57 PM Re: Timing of Credit Score Disclosure
DeeQ Offline
10K Club
DeeQ
Joined: Dec 2002
Posts: 40,760
Turnpike Exit 10
We are sending ours out with the early disclosures.
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

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#289399 - 12/15/04 09:06 PM Re: Timing of Credit Score Disclosure
Reg Wrecker Offline
Platinum Poster
Reg Wrecker
Joined: Dec 2003
Posts: 543
Kentucky
Ditto.
_________________________
Not even close to being legal advice....I have a bridge for sale too!

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#289400 - 12/16/04 05:51 PM Re: Timing of Credit Score Disclosure
corkygirl Offline
Power Poster
Joined: Sep 2004
Posts: 4,241
middle of the country
We are sending out the Credit Score disclosure listing the actual credit score within 5 days of pulling the credit report. I believe that the FACT Act states it must be within a "reasonable time" and to me waiting until closing is not a reasonable time. I know that we will get lots of calls either asking what this notice is or asking if this means their application has been approved. I'm in the middle of training all appropraite staff on all FACT Act effective as of 12/1/04, this being part of the training.
_________________________
Treading water in a hurricane

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#289401 - 12/16/04 09:07 PM Re: Timing of Credit Score Disclosure
Jack Holzknecht Offline

Gold Star
Joined: Aug 2001
Posts: 330
Louisville, KY
The FACT Act actually states that the disclosure is to be given "as soon as reasonably possibly."

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#289402 - 12/16/04 09:15 PM Re: Timing of Credit Score Disclosure
Anonymous
Unregistered

My copy says "as soon as reasonably practicable." The word "possibly" there doesn't make any sense.

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#289403 - 12/16/04 10:25 PM Re: Timing of Credit Score Disclosure
Jayda's Mom Offline
100 Club
Joined: Jul 2002
Posts: 220
North
Does this notice have to be signed by the consumer? I couldn't find anything that said a signature is a requirement.

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#289404 - 12/17/04 01:00 AM Re: Timing of Credit Score Disclosure
Chris Kilian Offline
Junior Member
Joined: Nov 2004
Posts: 47
Western Region
Here is a response to this very question I received from FDIC

"No, no signature or burden of proof. We'll be examining this by looking
at policies, practices, etc., just like any other disclosure. It's up
to each bank to decide how best to set up their program."

-Chris

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