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Using Previously Pulled Credit Report on New Loan

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I understand according to FACTA, a notice to the Home Loan Applicant disclosing credit score information is required, if a consumer applicant applies for an open or closed end credit that will be secured by 1 to 4 family residential real property. Our Bank automatically acquires this notice through our credit bureau reporting agency when credit is pulled. However, our procedures allow a Lender to utilize a credit report that has previously been pulled for some other transaction, as long as it is not older than a designated time frame. This may present a problem for us, since we do not need to pull credit on that customer to make a credit decision on this new real estate transaction. But, as part of our underwriting tool we are taking into consideration the contents and credit score of the previously pulled credit report. If we did not pull a new credit report, and obtain a new credit score to underwrite this new real estate transaction, are we still required to give the FACTA notice to the applicants?

Yes. Anytime you use a credit score on an applicable loan, you must provide the Notice to Home Loan. You can make an internal form for such an occasional.

First published on 3/27/06

First published on 03/27/2006

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