One of the banks wants to conduct targeted mailings for a particular loan product based on the past history of the demographic that has bought this product in the past. In this case that would mean marketing to individuals based on age, over 50 years of age. Would this be a fair lending issue, marketing based on age which is a prohibitive basis?
In lieu of the risk-based pricing notice, we use the credit score exception notice. It automatically prints every time we pull a credit bureau report. I understand the purpose of the risk-based pricing is for lending, but we also use the credit bureau report to determine if we will open an account. Is it permissible to give this credit score notice with an AAN when denying deposit accounts?
We have an ongoing disagreement in the office concerning the proper credit bureau reporting of loans, auto and real estate, that are taken out by individuals but are used for business purposes. Do we report these as loans made to the individuals or not report them at all because of the business purpose?
A National Bank customer defaults on an installment loan due to delinquency and the loan is charged off on December 31, 2002. The customer continues to make payments and brings the loan current in 2005. The customer asks the bank to rebook the charged off loan, the bank agrees and a new loan agreement is signed in March 2006. In December 2006, the OCC regulators tell the bank to charge off the new loan (their reason: a bank can not rebook a charged off loan) even though the loan was current and paid as agreed. Since the customer was not at fault and the bank was in error to rebook the loan, how does the bank report the loan to the credit bureau? Do they use the original date of December 2002 or December 2006?
I attended the Lending Compliance Roundup Seminar in Tulsa on March I. I understand that the easiest way to comply with the Risk Based Pricing Notice was to give the two pages from the credit bureau report- Your Credit Score and the Price You Pay for Credit. If we do give The Risk Based Pricing Notice stating that the interest rate would be effected, then must it be given to only the people it effects and not every customer?
We were wondering if there has been a recent change in the range of credit scores. We have noticed some scores above the 850 mark. We want to make sure we have the correct information that is stated on our credit score disclosures on our loans.
I have a prequalification (no property address) and ran joint credit (husband and wife). The husband’s credit scores are too low, but the spouse's scores meet investor guidelines. I have a credit analyzer tool that we have available through our credit bureau and I am working with the husband to try to increase his scores. At the same time, I’m getting a VOE on the spouse to see if she will qualify on her income alone. If the husband's scores cannot be improved, can he be removed from the loan, or will I need to do a declination and start over with just the spouse? Also, I have another loan that is joint and the borrowers qualify; however, the spouse's credit score is somewhat low and this affects the rate the borrower can obtain through our investors. The borrower wants the spouse removed from the application. Would we have to withdraw this loan and start with a new loan or can the co-borrower be removed without having to withdraw the loan and start over?
On April 12, there was <a href="http://www.bankersonline.com/compliance/guru2010/gurus_comp041210d.html">a question</a> concerning credit bureau reports and how to disclose them if the lender does not charge for a credit report. The answer was that it should be listed in Block 3 and a negative amount in Block 2. Which line would we check in Block 2? Why would this be shown as a negative amount on line 802, when the charge isn't for a specific rate but for a credit report? The answer didn't address the fact that the lender doesn't charge for a credit report. If we don't charge, do we still need to include it in Block 3?
Is flood insurance required on a property that the bank has foreclosed on and now owns? Notice of Default was filed, but we have been unable to sell the property. The loan balance has been turned over to the credit bureau for collection.
Do any privacy regulations require advance notice to report loan experience to the credit bureau? Can the customer opt out of such reporting?