05/13/2013
We had a customer wanting to know if she could qualify for 100% financing. We had her sign a credit authorization. Her scores were not high enough to qualify for the 100% financing. We did not take an application - adverse action necessary?
04/22/2013
We would like to start charging for credit report fees at our financial institution. Are there any fair lending considerations that we should be aware of (especially where pulling joint credit bureau reports is concerned)?
08/27/2012
If an applicant starts to apply for a mortgage loan online and early in the process authorizes a credit bureau to be pulled but then never submits the application, are we required to do anything with the information such as send a letter of notice of incomplete application and report on HMDA LAR or is this considered an inquiry that never resulted in a HMDA application?
07/23/2012
Does the Fair Credit Report Act apply to Business accounts?
04/16/2012
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?
01/23/2012
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?
01/16/2012
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?
11/21/2011
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?
05/16/2011
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?
11/01/2010
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.