04/30/2007
I was always told to obtain a credit authorization signature (either a signature or valid electronic signature) prior to running a credit report. In a recent meeting, I was told that you could obtain a credit report through a verbal credit authorization (without obtaining a signature from the customer) as long as you read them the FCRA. Is this true or false? In what Reg would I be able to find the answer?
03/19/2007
If a bank uses an outside investor to fund a mortgage loan and the credit report is generated from that investor's website and that investor's name is on the report, can the bank impose a credit report fee at closing? The bank is not charged for the report, it is part of the investors "underwriting fee" that is ultimately charged to the customer.
03/12/2007
Our lending department wants to set up an online process where customers can submit a loan inquiry from our Web Site that would include almost all of the information that is on a normal face-to-face application. The information gathered would only be used, and a credit report run, once a face-to-face meeting has occurred. They are looking for a way to speed up the application process for the customer. I would like to know if this is possible or would it be considered that we have really received an application when we receive the information from the Web site?
11/27/2006
If you turn a consumer down for a loan and the consumer asks for a copy of the credit report that the lender pulled, can you give him a copy? Where is this located in the Reg?
09/25/2006
A loan processor was in the process of running a credit report on a customer and the wrong customer information was uploaded into the system. Therefore, the credit report was run on the wrong customer. What should we do to correct this problem, do we contact the customer and let him know the report was run in error?
09/18/2006
My question is about Supervisory Loan to Value. We do a first and piggy back second mortgage loan on a customer’s primary residence and the LTV is over 90% on the combined first and second. We report this as an exception to our board and sell the first on the secondary market and keep the second in house and continue to report the loan as an exception to SLTV. Is there a time frame in which we can "assume" the principal on the first has been reduced enough to stop reporting it?
04/03/2006
My question relates to the FCRA and the ability of a bank, or other lending institution, to internally cross-sell. Let's say that a bank does a credit check (for a proper purpose under FCRA) to determine whether a potential borrower would be approved for a mortgage. Based on the information contained in the credit report, the bank then solicits the potential borrower to also obtain a HELOC. The HELOC is also done through the bank, although in a separate department, and another credit check would be pulled in connection with the HELOC if it was pursued by the potential borrower. Is this prohibited by FCRA? I have looked at the provisions of the act and it does not seem to be expressly prohibited.
03/13/2006
We want to start a promotion where we notify customers that they have been pre-approved for a Home Equity loan, what guidance can you provide and what regulation should I look at?
10/26/2005
Shopping Dealer Paper under the FCRA
By BOL Guru John S. Burnett
09/19/2005
I understand that once an application is taken and credit is pulled the lender has 3 days to mail or have the customer sign RESPA GFEs. However, what does a lender do if the customer is looking to purchase a home or is just shopping and the information to complete the application or GFE is insufficient such as loan amount, etc. What does the lender do at this point?