AAN - Information from an Outside Source

Posted By: Mel in WA

AAN - Information from an Outside Source - 02/08/17 05:47 PM

We are converting to a new LOS and updating our AAN. The vendor is providing a sample AAN that matches the model notice in Regulation B, except for the verbiage below:

"Our credit decision was based in whole or in part on information obtained from an affiliate or from an outside source other than a consumer reporting agency. Under the Fair Credit Reporting Act, you have the right to make a written request, no later than 60 days after you receive this notice, for disclosure of the nature of this information."

This is on our current AAN, but rarely (maybe never) used. Most of the time, it's marked in error. Is it acceptable to leave it off?
Posted By: David Dickinson

Re: AAN - Information from an Outside Source - 02/08/17 10:13 PM

It is rare to use this and I don't believe you need to have it on the form, unless it is applicable. IOW, you don't have to have all info that is possible and then mark boxes to indicate what is applicable. Some systems print "tailored" disclosures and only provide applicable sections. If this is not applicable to 99 out of 100 applicants, you can leave it off. But what are you going to do when you have that 1 that needs this disclosure?
Posted By: MScarn6942

Re: AAN - Information from an Outside Source - 10/06/17 03:37 PM

Just to check - is information the borrower provided considered an outside source? One gave us an appraisal she had done for her and a loan amount and the LTV is too high so it was denied. Is that considered an outside source?
Posted By: rlcarey

Re: AAN - Information from an Outside Source - 10/06/17 04:02 PM

No - and since the appraisal was totally not acceptable for use by the bank, how can you make your judgement using it?