Commercial vs. Consumer Disclsoures

Posted By: LAK

Commercial vs. Consumer Disclsoures - 03/19/13 06:17 PM

I realize this should be one of those questions that is water under the bridge and we should all know but...
Consumer loan request we provide the Exception Notice (Credit Score Disclosure) and the Notice to the Home Loan Applicant (as applicable) when a credit report is used in whole or in part to make a credit decision. Clear as the blue skies.

Commercial loan request new world does not provide either when personal credit is considered if it is for comercial/ag purposes and coded as such. In my previous world, staff was instructed to provide both disclosures (as applicable) if personal credit was considered for personal guaranty, co-signer, co borrower and negative info is reported to a credit reporting agency on a commercial credit request.
The credit reporting agencies are set up to not print the disclosures as they are commercial.

I have been researching the threads but like everything else they all have a bit of a different twist. What it comes down to, are we compliant due to the commercial credit request in not disclosing either disclosure? I have read that business purpose credit is excluded. So is business/commercial excuded in whole or inpart? I would love the clear as blue skies here too?

Thanks in advance!
Posted By: Ted Dreyer

Re: Commercial vs. Consumer Disclsoures - 03/19/13 07:10 PM

Business purpose credit is excluded for both Risk-Based Pricing and the NTHLA.
Posted By: LAK

Re: Commercial vs. Consumer Disclsoures - 03/19/13 08:05 PM

Ted, thanks. I saw your previous post, but had to continue with our due diligence to make everyone happy. To ensure we are talking the same disclosures, we provide the H-3 Exception Notice & NTHLA. We are still on the same page? Business/commercial credit request, they are N/A. Thanks!!!
Posted By: Ted Dreyer

Re: Commercial vs. Consumer Disclsoures - 03/20/13 02:35 PM

Yes, we're on the same page - both are for consumer purpose only.