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#2017204 - 05/30/15 04:46 PM Evidence of the Credit Score Disclosure
Newbie06 Offline
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Joined: Mar 2006
Posts: 738
If you are supplying your customer with the Credit Score Disclosure that prints out with the credit report how are showing evidence that it was given to the customer?

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#2017213 - 05/31/15 02:27 PM Re: Evidence of the Credit Score Disclosure Newbie06
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
It should be documented through procedures. Some credit bureaus mail it direct for an additional fee.
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#2017248 - 06/01/15 12:25 PM Re: Evidence of the Credit Score Disclosure Newbie06
Michelle M. Offline
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Joined: Jun 2014
Posts: 13
How do you recommend documenting the file if the credit company is sending it? We sell our loans to investors, and I assume they will want to see proof on every file.

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#2017250 - 06/01/15 12:27 PM Re: Evidence of the Credit Score Disclosure Newbie06
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
A copy is generally given to the bank, and you have your contract with the credit bureau.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2017257 - 06/01/15 01:38 PM Re: Evidence of the Credit Score Disclosure Kathleen O. Blanchard
Newbie06 Offline
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Joined: Mar 2006
Posts: 738
The bureau is supplying us with the notice and it's being given to the customer. You can tell this is happening because when the report prints it prints with the number of pages (page 6 of 9). So, the file is left with the report ending on page 6 and pages 7-9 are given to the customer. An external auditor is saying that we don't have evidence of the credit score disclosure in the file.

Are other banks have the customer sign another piece of paper acknowledging they received the disclosure?

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#2017264 - 06/01/15 01:52 PM Re: Evidence of the Credit Score Disclosure Newbie06
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Perhaps some other users can advise. I have never seen a bank get written acknowledgement. What a waste of paper.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2017295 - 06/01/15 03:28 PM Re: Evidence of the Credit Score Disclosure Newbie06
Adam F Offline
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Adam F
Joined: Apr 2013
Posts: 420
VA
We do not have the customer sign any type of acknowledgment for this disclosure.

We just keep a copy of the disclosure in file with the credit report and indicate in our procedures when the notice is to be given. Haven't had any issues with anyone on this so far.
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It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2017314 - 06/01/15 04:12 PM Re: Evidence of the Credit Score Disclosure Newbie06
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,783
The Mitten State
We maintain a copy in the file.
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Nonsense wakes up the brain cells.

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