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#857 - 03/06/01 08:18 PM Loan Participations
Gary R Offline
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Gary R
Joined: Mar 2001
Posts: 4
Oklahoma, USA
What effect do the FCRA and GLB Act have on Loan Participations? I can't seem to find anything that addresses participations.

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General Discussion
#858 - 03/06/01 08:21 PM Re: Loan Participations
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Correct me if I am wrong, but I understand that loan participations would be treated in a similar manner to loans that are sold on the secondary market - and therefore exempt from the Privacy opt-out and prohibitions on information sharing under FCRA.

It is part of the actual servicing of a transaction initiated by the consumer.

Now, if the participation is for a business loan, hopefully you have the authorization in file from the principals to have run their consumer credit reports.

Regulations are a poor substitute for ethics.
Just sayin'

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#859 - 03/09/01 03:30 AM Re: Loan Participations
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
How does this also affect correspondent relationships? We've been asked this by an out of state correspondent whose state privacy regulation will be more stringent than the federal regulation. In addition, the state correspondent will have an opt-in while our is an opt-out. Our state has not yet adopted its own privacy requirements.

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