If you do a preapproval/prequalification where you have five pieces of information (not the property location) and the customer is approved for an amount but the customer never comes back to the bank. What is the proper procedure in this situation?
In regards to the check box options on an adverse action notice, as a commercial lender, I would like to add “Length of time in business is too short” as we do deny credit to many newly established companies (per our credit policy), so my question is this: Can I create my own reason(s) or are there a specific set of reasons that I need to adhere to? Where does ‘length of time in business too short’ (or verbiage to that effect) fit on an adverse action notice?
If you use a vendor that provides scores from all 3 bureaus and you only use the score/reasons from one bureau for the denial, do you use that specific bureau's name and address or the actual vendor that supplied the report for your adverse action?
Can credit be denied based on a credit report pulled over 6 months ago or should a new report be pulled? (In this case, the credit requested 6 months ago was denied and now a new credit request has been received.)
We mailed the borrower’s Loan Estimate and they emailed us that it was received, and they want to proceed with the loan. Can we act on this emailed notice?
When will HUD’s SCRA mortgage notice be updated?
With regards to the Fair Credit Reporting Act - Review and Update Webinar described at https://www.bankersonline.com/webinars/fcra0617 - should all the topics listed under the Program Content be addressed in a Credit Union's Policy ( except those for the consumer reporting agencies)?
If we deny an application for a consumer installment loan from a consumer who applies with a cosigner, do we need to send an adverse action notice to the cosigner?
Adverse Action Webinar - June 21, 2017 - David Dickinson
I wanted to confirm. David Dickinson said in a recent webinar that if a consumer comes into the bank to inquire about a loan and we know from the initial conversation they will not qualify and after explaining our basic underwriting guidelines we can provide them with an adverse action notice on the spot. We would no have pulled credit. We would not have discouraged them from applying.
Would we use form C-1 to provide the notice?
We would of course keep any documentation with the notice for retention and Fair Lending audits and risk assessments. We would also provide training to our LO's and provide them basic scripts.
Am I on the right track?
Under Regulation B, there is a separate definition for an application and a completed application. Is there a requirement to monitor and track for an application and a completed application?