12/20/2015
We are dealing with the problem of credit reporting on bankrupt accounts. Our reporting is done at the loan level therefore non bankrupt co-borrowers are affected. Can we just suppress reporting?
10/04/2015
If a borrower was denied credit for insufficient income (non credit score related),
does the credit /score disclosure need to be included with the denial letter?
07/12/2015
What regulations cover information for furnishers of credit information to CRAs. FCRA appears to cover the majority of it, but there is one section of Reg B (1002.10) that covers the requirements for reporting spouses. Are there any other regs that discuss the requirements of the furnishers of credit information?
04/27/2015
If a customer has a physical address and a PO Box as a mail to, which address should be used when obtaining a credit report?
01/26/2015
Under the Fair Credit Reporting Act, if a direct dispute is deemed to be frivolous or irrelevant, the Bank shall notify the consumer of such determination not later than 5 business days after making such determination. Do you have a sample of the frivolous or irrelevant notice, or can you indicate where one can be found?
04/21/2014
I noticed on invoices on CBC credit bureaus the company is charging additional fees besides the cost of running the credit bureau. The fees include items like a $9 charge to update credit bureau records. $55 charge for something called 3 system residential mortgage. The bank passes these costs on to the customer on the GFE as credit bureau fees when the actual cost of the running the bureau is ~ $20.90. Should the bank be passing the extra charges from CBC on to the customers which do not appear to be costs of the actual bureau? No other credit bureau service appears to be adding charges to their bills.
07/01/2013
These are general RESPA questions that have recently been proposed by Management and we would appreciate your expertise.<ol><li>Do we have to itemize Hazard Insurance on the GFE for a home equity loan when the Hazard Insurance is already in place? It is my understanding this is a requirement on the GFE because we require the Hazard Insurance to be in place before making the loan therefore it is a cost of the loan.<li>If all the fees are paid by the lender except for the origination fee, do we need to itemize each fee paid by the lender on the GFE? Doing this gives the wrong impression to the customer that they will owe fees that they actually won't have to pay.<li>If your answer is yes to #2, could we show a credit on the GFE for the fees being paid by the lender? Doing so would bring the final fee disclosed to reflect the actual amount being paid by the customer. Another related-question would be what line would the credit be reflected on the GFE? </ol>
05/27/2013
We are charged from our vendor for credit reports. The charge depends if it is individual or joint credit report. We can only charge the amount that we are charged from our vendor, is that correct? Let's say the highest charge is $21.75 then we can not charge more then $21.75.
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)?