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?
Can a bank say they don't have a "completed" application (for Reg B purposes) until they have the 6 pieces of information required under TRID? And if yes, should it be documented in the procedures?
Can you clarify when the “marital status” section should be completed on an application that is not for the purchase or refinance of the applicant’s principal residence? We are not located in a community property state.
If we have a signed application for a TRID loan, can we pull a credit bureau before receiving the customer’s intent to proceed?
Can you confirm joint intent must be collected at application and not at the time of a completed application?
I am looking for regulation that allows a creditor to obtain credit scores for existing customers to use for monitoring and tracking purposes, or restricts such purpose. For example, quarterly tracking of a customer's credit score to detect any deterioration that may also then be used for adverse action on a consumer line of credit such as suspending the line. Another example is to track improvement of credit scores where the creditor has granted consumer a loan for the purposes of credit repair or establishing a credit history.
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?