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Monthly Report on New Loans Documentation

Question: 
During a review of new loans for the previous month, I found that a joint credit report (husband/wife) was pulled for a new loan that was made to just 1 of them (the wife). The previous loan was a joint loan and a joint credit report was used then How do I need to document this finding in my monthly reports? Along with some additional training for the loan officer, what other things should I be aware of and keep in mind?
Answer: 

I am sure they have been previously trained and if so, make sure you show them this.

Sec. 616. Civil liability for willful noncompliance

(b) Civil liability for knowing noncompliance. Any person who obtains a consumer report from a consumer reporting agency under false pretenses or knowingly without a permissible purpose shall be liable to the consumer reporting agency for actual damages sustained by the consumer reporting agency or $1,000, whichever is greater.

and this:

Sec. 619. Obtaining information under false pretenses

Any person who knowingly and willfully obtains information on a consumer from a consumer reporting agency under false pretenses shall be fined under title 18, United States Code, imprisoned for not more than 2 years, or both.

First published on 12/08/2019

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