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#608194 - 08/31/06 08:31 PM Credit Score Policy
laf0915 Offline
100 Club
Joined: May 2006
Posts: 236
Is it a regulation that you must have a credit score policy in your banks loan policy. Such as stating something like we make no loans to anyone with a credit score below a certain amount without board approval?

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Lending Compliance
#608195 - 08/31/06 08:38 PM Re: Credit Score Policy
Dazed and Confused Offline
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Dazed and Confused
Joined: Feb 2006
Posts: 250
Big XII South
I am not aware of any regulation that requires credit-score-based lending. It is up to the discretion of the board and/or lending management if they want to incorporate lending policies and practices that are tied to credit scores. If your bank does not have any discriminatory lending issues based on existing practices ... I would steer clear of a credit scoring policy. Otherwise ... the bank will inherently experience "deviations" and "over-rides" from the credit scoring policy ... which will then require adequate documentation to support the deviation ... which could then result in criticism by the regulators since the bank frequently deviates from the credit scoring policy ...

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#608196 - 08/31/06 09:15 PM Re: Credit Score Policy
Dazed and Confused Offline
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Dazed and Confused
Joined: Feb 2006
Posts: 250
Big XII South
And if you are interested in credit scoring policies ... refer to the following regulatory guidance ... (and simply enter "credit score" in the search field of each file) ...

FDIC Exam Manual
http://www.fdic.gov/regulations/safety/manual/section3-2.html#creditScoring

OCC Guidance (references obtained from the OCC lending booklets)
http://www.occ.treas.gov/ftp/bulletin/97-24ATT.pdf
http://www.occ.treas.gov/ftp/bulletin/2000-16.doc

Interagency Fair Lending Exam Procedures
http://www.fair-lending.com/Documents/Interagency%20FL%20Guidelines.pdf
http://www.fair-lending.com/Documents/Appendix%20to%20Interagency%20FL%20Guidelines.pdf

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#608197 - 09/14/06 03:23 PM Re: Credit Score Policy
Ninky Offline
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Ninky
Joined: Nov 2002
Posts: 357
New to credit score pricing. When rates are tied to credit scores, what APR does your lender quote when talking to customers? Your best and worst rates, or something in the middle? Cannot find any standards or requirements on this. You obviously do not share your score/pricing tiers, but in the best interest of both parties, you also don't want to misrepresent. What is industry practice?

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#608198 - 09/15/06 09:14 PM Re: Credit Score Policy
garcia_audit Offline
New Poster
Joined: Sep 2006
Posts: 1
Does anyone have a sample credit score policy that they would share?

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