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#2274880 - 08/29/22 09:02 PM Copy of Driver License in a Denied File
Compliance Newbie Offline
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Joined: Jan 2015
Posts: 79
Should a copy of the applicants Driver License be scanned in with the Notice of Action Taken? (Denial)

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Lending Compliance
#2274882 - 08/29/22 09:07 PM Re: Copy of Driver License in a Denied File Compliance Newbie
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
While you have some CIP responsibilities if a loan closes, why would scan and retain a copy of an ID for a denied loan file when that could contain prohibited information under the ECOA?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2274884 - 08/29/22 09:22 PM Re: Copy of Driver License in a Denied File Compliance Newbie
Compliance Newbie Offline
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Joined: Jan 2015
Posts: 79
Does the Regulation state that it should not be included?

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#2274887 - 08/29/22 09:29 PM Re: Copy of Driver License in a Denied File Compliance Newbie
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Well, let's see, from a picture ID I can usually tell sex and race and age. Last I checked those were prohibited basis under Regulation B. So, unless you were collecting the ID for CIP purposes, which would not apply since you are not establishing an account, what business would a picture ID have in a denied credit file other then to possibly be used in the credit denial process? That is not a discussion that I would want to even be within 10 feet of with a regulator.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2274893 - 08/30/22 12:18 PM Re: Copy of Driver License in a Denied File Compliance Newbie
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Joined: Jan 2015
Posts: 79
Thanks. Now that makes sense.

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