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Allowed to Pull Credit Report w/o Signed App?

When an originator takes a phone application, what is acceptable by the regulators that all the proper disclosures have been provided to applicant? My other concern is can we still pull a credit report with written authorization from applicant? ( This usually being provided by a signed application.) I was and still am under the impression that credit should not be pulled until you have an application.

Answer from Randy: If you have an application for credit, you have a permissible purpose to pull a credit report. A signature by the consumer is not a requirement. As far as documenting delivery of disclosures, I'm not sure that I understand the question, but most banks attach a dated cover letter to the multitude of initial disclosures that are required to be delivered for proof of mailing date.


Answer from Andy: Proof to a regulator is the same proof you want when you audit this. To know that disclosures are made, you look for the copies in the file, the dates and completeness. You look for notations in the files and you ask the staff involved what the procedures are, when they are done, and what the staff does if this can't be done for some reason. Essentially, what is in the file and if there wouldn't be evidence in the file, what is the SOP that is followed and is it always followed. As to the credit bureau access, your permissible purpose could include an application the applicant completed, that your staff completed, or an oral application. In case of the latter, I recommend detailed notes.

First published on 7/15/13

First published on 07/15/2013

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