Can a consumer be declined for credit when they qualify for the credit or if they have been approved for credit at the institution previously?
Situation - Applicant has applied several times for credit with the financial institution. All loans have been paid according to terms on the two loans currently on the books. Prior paid off loans always paid off as agreed. Never any late pays. The bank approved the two prior loans with their credit score in upper 500 range due to a deed in lieu of foreclosure on a previous property. The applicant has now increased their score to upper 600's to lower 700's depending on which credit report you look at. There are no past dues on their CB reports other than the deed in lieu from a couple years ago. Their DTI ratio is within policy guidelines with the bank. The one of the loans on the books has two policy exceptions that were already approved and being tracked. The same applicant applied to increase this particular loan and extend out one more year. The bank declined them; however has not yet given them a reason why. Can this be considered a fair lending issue since they qualified with income and due to bank already approving prior loans with the above mentioned exceptions? The same two exceptions would exist on this new loan with no new exceptions to mention. Seems like discrimination to me.
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?
Normally we do not use credit score when determining rates or approvals. However, we are offering a promotion and want to base the rate on their credit score for this promo only and no other loans. Are there any discriminative factors in doing so as long as we apply the same procedure fairly to each applicant that applies.
A borrower does not meet VA (or FHA) net tangible benefit for refinancing. What would be an appropriate reason for Statement of Denial?
I’m trying to create a risk based pricing model without any historical data. Any ideas?
Is the second review of declined mortgage loans a regulatory requirement or a Fair Lending best practice? If required, what regulation? Would the review be applicable to loans auto-declined by a credit scoring system?
To what extend does Reg B apply to an automated small business credit scoring program (eg. notice, adverse action, etc).
It is talked about in many contexts. It is a term tossed about without clear definition. It engenders fear and caution among lenders. It raises compliance concerns.
The FTC has solicited comments on its study of the effect of credit scores on the availability of insurance and credit products.
Are there potential fair lending issues if we use credit scoring for dealer paper credit decisions and pricing, when all of our other traditional loan products use other criteria?