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#89729 - 06/19/03 04:00 PM Indiredt Lending - CIP
BBC Offline
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BBC
Joined: Nov 2001
Posts: 21
NoCal
Two issues I need some assistance with (I’ve done a search but, I’ve been unsuccessful in finding anything).

For those of you doing indirect lending when the loan is closed in the name of the bank:

1) how much of the id and verification process are you relying on the vehicle dealers to do? How are you accomplishing this? Additional forms? Part of the app? Are you requesting the dealer obtain the driver’s license number or are you relying on the credit bureau to verify id?

2) How are you getting the Identification Notice to the borrower? Is the dealer now required to do this? If so, how? An additional form?

Any ideas of what works and what doesn’t would be appreciated Thanks:)
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#89730 - 06/19/03 04:24 PM Re: Indiredt Lending - CIP
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
1) Since the dealer is not a business that you can "rely" upon under (b)(6) of the regulation, you would be responsible for their actions. Unless you have a great deal of confidence in them, you might want to do the verification yourself by nondocumentary means.
2) You mentioned an app in the first part of your question. If there is a standard application form, why not put the adequate notice at the top?

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