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Latest Lending - Reg. V Topics

"XYZ Data" on Adverse Action Notice

08/25/2019

I have a client (a lender) who orders their credit reports from "XYZ Data" and when a loan is declined, they list Equifax on their Adverse Action Notice (with appropriate address and phone number) and they have now been told that because "XYZ Data" is considered a reseller of credit under the FCRA 603(u) that they should also list XYZ Data (along with its name and telephone number) on the Adverse Action Notice. Is this true?

Denied Due to Collateral & Adverse Action Notice

06/30/2019

If a loan is denied due to collateral value, would the adverse action notice include that an outside source was used in the decision and the outside source was the appraiser? I believe the appraiser would NOT be an outside source for this purpose.

Fraud Alert on Consumer Credit Report

01/08/2017

If there is a fraud alert on the consumer credit report, is the creditor required to attempt to contact the consumer at the phone number on the fraud alert message, or can the creditor just decline the application and not bother with trying to contact the consumer?

Borrower Denied Credit for Insufficient Income

10/04/2015

If a borrower was denied credit for insufficient income (non ​credit score related)​,​ ​d​oes the credit /score disclosure need to be included with the denial letter?

Sample of Frivolous or Irrelevant Notice

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?

Regulation V Info Regarding FCRA & FACTA

08/18/2014

I am wondering what part Regulation V plays in FCRA and FACTA? I have been asked to review this for my next test and would like a little more insight into it.

Most Popular Lending Content

Is email receipt of the LE sufficient

01/19/2020

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?

MIL - Open-end and ODP Coverage

01/19/2020

The Military Lending Act does not specify if the Act applies to an open-ended Overdraft Protection line that is tied to a checking account or a closed-ended loan secured by the applicants’ deposit accounts such as a savings and/or certificate of deposit. Does the Rule apply to both consumer credit types?

Rate Spread for HMDA on a Construction-Permanent

01/19/2020

When reporting the rate spread for HMDA on a construction-permanent loan, should the rate spread for the construction phase be reported or the permanent phase, which will take place a year later?

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