Thread Options
#84135 - 05/30/03 10:53 PM FCRA
Cowboys Fan Offline
Power Poster
Joined: Dec 2002
Posts: 4,598
SC
We have a consumer who states that, under FCRA. we are obligated to follow up with the credit bureaus to ensure that they are loading our tapes immediately. I can't find anything like that - does anyone know if this is accurate?

Also, this same borrower (no late payments) is asking us to provide written responses to his inquiry regarding our bank policy on when we send tapes, how we verify that the info is accurate, how we follow up to make sure it's been updated, and on and on and on!!! What is our obligation in our response to him - how much info do we share with him, especially since he's stated that it will shared publicly?

Thank you for any help you can give - I'm ready to scream
_________________________

Return to Top
Lending Compliance
#84136 - 05/30/03 11:22 PM Re: FCRA
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,762
Bloomington, IN
I know of no such requirement. If I'm not mistaken this is usually a contractual issue (I know a few companies still only report on a quarterly basis instead of monthly) between you and the CRA. Have the customer give you the applicable citation.

Again, IMO, you have no obligation to reveal your internal procedures to be released to the general public.

I think I'd tell this customer that his requests are now crossing the threshold into "legal territory" and request that he have his attorney contact yours, and no further information will be released without legal representation and research and since he is requesting the information he'll will be responsible for the research costs and they will have to be paid before any information is released. That usally will shut them up.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#84137 - 05/30/03 11:42 PM Re: FCRA
Cowboys Fan Offline
Power Poster
Joined: Dec 2002
Posts: 4,598
SC
Thank you so much for your quick response - I can now have a "non-research" weekend!!
_________________________

Return to Top
#84138 - 05/31/03 04:28 AM Re: FCRA
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,485
On the Net
Perhaps the customer spoke with an attorney or law student who also recommends depositing checks as cash under the UCC to avoid holds.

Unless there is a state requirement otherwise, the FCRA isn't going to require this and when you report credit information is not the customers business, only that you report correct data.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#84139 - 06/01/03 12:14 PM Re: FCRA
DeeQ Offline
10K Club
DeeQ
Joined: Dec 2002
Posts: 40,763
Turnpike Exit 10
Quote:

Perhaps the customer spoke with an attorney or law student who also recommends depositing checks as cash under the UCC to avoid holds.





That was funny!
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

Return to Top
#84140 - 06/02/03 04:22 AM Re: FCRA
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Or perhaps he's friends with the person who wanted to open a business checking account with very shakey documentation. He claimed that "CRA mandates" we open the account for him.

I'll see your CRA, and raise you a CIP!!!
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#84141 - 06/02/03 03:24 PM Re: FCRA
NotALawyer Offline
Gold Star
NotALawyer
Joined: Nov 2001
Posts: 455
Good one! Wait, I'm laughing at an inside joke about (gasp) regulatory acronyms (yawn)...oh, boy...and it's only Monday...

Return to Top
#84142 - 06/02/03 05:24 PM Re: FCRA
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Robert - it takes very intelligent people to understand and appreciate Compliance Humor.

Keep telling yourself that. It helps.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top

Moderator:  Andy_Z