Posted By: upstateNY
C-signers and Notice of Negative Information - 09/22/05 01:24 PM
I have gone back and looked at old posts addressing the requirement (or not) to provide the notice of negative information to co-signers. I'd like more current opinions please. We are automating our consumer loan documentation prep. Our vendor is emphatic that a "co-signer" does not need to receive the Notice of Negative Information (NNI) under Section 623 (a)(7) of FCRA. The vendor's logic is that this applies only to "parties that have requested credit".
They are not willing to budge on this. I'd like to be well informed when I go into another round of discussion with them tomorrow.
We have chosen to provide the notice at the time the new loan account is established. We do provide information on co-signers and guarantors for consumer-purpose credit to the credit bureaus. Hence, my opinion is that they should also receive the NNI.
Is there any loophole that excludes co-signers and guarantors from the provisions of the FCRA and FACT Act for purposes of this Notice? I am concerned about the definitions of "consumer" vs "customer" and how the two words are intermingled in the FCRA
Any comments would be greatly appreciated.
They are not willing to budge on this. I'd like to be well informed when I go into another round of discussion with them tomorrow.
We have chosen to provide the notice at the time the new loan account is established. We do provide information on co-signers and guarantors for consumer-purpose credit to the credit bureaus. Hence, my opinion is that they should also receive the NNI.
Is there any loophole that excludes co-signers and guarantors from the provisions of the FCRA and FACT Act for purposes of this Notice? I am concerned about the definitions of "consumer" vs "customer" and how the two words are intermingled in the FCRA
Any comments would be greatly appreciated.