I am creating lender training material and finding out that what I thought I knew very well as a lender I don't know as well as I thought, certainly not as well as I need to now as a compliance officer. Perhaps I was trained a certain way and it is not a regulation. I have believed that a lender needs written permission to obtain a credit report. I am told that the part of ECOA that addresses written permission pertains to a consumer needing to provide written request to obtain their own report from a credit reporting agency. I can see that I could be wrong. AM I? We follow up verbal credit requests with a written application signed by the borrower but obtain the credit report upon the verbal request. My problem is that I see credit reports dated prior to the date of the application. I am also having a problem trying to explain that a credit report is for a single purpose. Everyone thinks I am too literal which can be true.

I hate to waste people's time. I searched everywhere except under "applications" in the infovault. I did just find quite a bit of info there and I might order the BOL seminar material on applications and pre-quals and pre-approvals.

Unless it's a state specific requirement, you don't need written authorization to run a credit report. However, you do need a legitimate business reason/purpose to do so.

And, while widely abused, a credit report used for credit analysis is not supposed to be used for cross-selling.