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#1372946 - 04/12/10 09:58 PM Adverse Reasons Chart
morirse de risa Offline
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Joined: Feb 2009
Posts: 238
Midwest
Are the explanation listed in the BOL Adverse Reasons Chart based on a reg or intrepretation?

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Lending Compliance
#1372952 - 04/12/10 10:29 PM Re: Adverse Reasons Chart morirse de risa
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
It appears that they are based at least on the Sample Notices in Appendix C of Regulation B.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1372953 - 04/12/10 10:34 PM Re: Adverse Reasons Chart Doug Hendrickson
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
While I'm at it:

We use what appears to be an older standard form from a vendor that also lists, under OTHER the reasons that "We do not grant credit to any applicant on the terms and conditions you requested".

I'm uncomfortable with this, as I would think that we then should document the terms/conditions requested and the terms/conditions we could offer and really give a counter-offer and let the customer decline the counter.

Does any one else use the above terminology and, if so, how do you handle the documentation?
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1373019 - 04/13/10 12:59 PM Re: Adverse Reasons Chart Doug Hendrickson
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
I agree you should be specific such as we don't offer 84 month auto financing but you are under no obligation to make a counter offer on terms you do offer.
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The opinions expressed are mine and they are not to be taken as legal advice.

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