CSDS Provided Prior to Closing?

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Question:

Are we always required to provide the Credit Score Disclosure Statement(CSDS) prior to closing on all real estate, including interim construction (short-term with permanent take-out letter)? The credit bureau report is provided by the permanent take-out lender.

Answer:

If you are referring to the Notice of Home Loan Applicant [Section609(g)(1)], it applies to all consumer purpose loan applications for a loan secured by a 1-4 family residential dwelling and the institution uses a credit score. If your institution used the credit score, you must provide this disclosure. If the permanent lender used the credit score, they should provide the disclosure. One further note: The disclosure isn't required "prior to closing." It is to be provided "as soon as reasonably practicable". I recommend you provide it with the Good Faith Estimate.

First published on BankersOnline.com 1/28/08