Struggling this morning... we own a mortgage company (a subsidiary) and they have a credit report that they want to give to us for our 2nd mortgage loan. Can we share? Or will the mortgage company be considered a CRA? They are not a "department" of the bank - they are separate as far as they do their own HMDA LAR but they are reported with us on the call report.

Not sure I understand the facts fully, but affiliate sharing of consumer reports is permissible provided you have made the proper disclosures and opt outs.

You should review section 624 of the FCRA and be sure your affiliate is prepared to comply with those requirements.