I know there has been discussion regarding whether or not we need to get a signed copy of the credit score disclosure to retain in the file. The FACT Act does not appear to require it, but it may be a "best practice". It may be practical in a face-to-face situation but not for mail-in or phone applications.

My question involves adverse actions. I don't think it makes since to have a place to sign on the credit score disclosure in this instance. They would never sign it anyway. SO, should I do one form with no signing blanks that fits all scenarios or do two forms, one where it can be signed and one where getting it signed is unlikely?

Opinions? (Sorry for running on about it...)

Oh my goodness...I can't believe I typed "since" instead of "sense"! In my defense, "I hab a code in my dose" and am clearly not thinking straight!

Ahhhhhh....CHOO!

Our disclosures will not have signature lines. We just added a short sentence in our procedures that the notice will be provided within 3 to 5 business days of obtaining the credit report or in the case of an adverse action with the AAN if the loan is denied with 3 business days of the application date. We will place copies in the file.

We do not have ours signed either, we keep a copy in the file and it is part of our procedures.

Thanks...I tend towards overkill at times...

NCMountainMan