Notice to Home Loan Applicant on Inquiries

This is somewhat piggybacking off a question I asked and had answered last week but posting it in a different thread since it is slightly different.

If we have a inquiry that we deny we owe the borrower an AAN and NHLA (both containing the credit score information if credit was a reason for the denial). What I am not 100% certain on is if we have to give the NHLA disclosure for an inquiry that is not denied (one that we issue a prequal letter on and doesn't go anywhere). 1002.9 seems to state that an inquiry is not an application unless you take adverse action. The FCRA's NHLA requirement applies to applications for credit.

Thoughts??

What was your permissible purpose to pull credit if you did not have an application?

You can pull credit on a prequal, terpsfan.

Here's a previous thread on this topic. Hope it helps.

Currently we do have all "prequals" documented on an application but what the lenders are saying is a lot of these are actually more in the inquiry camp where the applicant is wanting to know based on their credit what program would be best or if they would even be able to get a loan.

The lenders are taking issue with having to give the NHLA disclosure to an applicant where an applicant is just fishing to see if they could even get a loan. This is extra time and expense in generating and mailing these to these "fishing" applicants. Just thought I would throw it out here to see how others are treating this.

I consider a prequel an application under FCRA just not under Reg B and RESPA and we provide the NHLA for prequalifications.

We were just wondering if we could potentially get these into more of an inquiry (which is really what a lot of our current prequals are) and if so, is a NHLA required on an inquiry.

terpsfan and I have both said that no matter if you call it a prequal or an inquiry, if you're pulling a credit report, give them the NHLA, as did Dan in the thread I linked.

I don't see how it's such extra time and expense. Our cbr prints it as part of the rest of the report. You should be able to set yours likewise.

We have that too. They're growling about having to print it out and mail it!