Adverse Action Notices
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  1. #1
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    Adverse Action Notices

    What are your feelings about the Adverse Action notifications now going out from some lenders/funders?

    Will it make doing business more difficult with the A paper folks as they send Adverse Action emails to all declined applicants, or do you welcome them proactively complying with the Equal Credit Opportunity Act and Fair Credit Reporting Act?

    Does encouraging a declined client to have a direct line of communication to the lender/funder (outside of your relationship with them) to investigate the reasons for denial worry you?

    Or, will it serve to help to sell the higher cost funding due to the explicit conforming to laws and offers of transparent reasoning behind denials. While revealing the strictest underwriting approvals as being for the very few? (like when a merchant comes back to you after trying for a bank loan hat-in-hand)

    No matter what, it is a big step in an unknown direction...

  2. #2
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    Problem is when funders decline deals due to: “missing daily payments” when this is supposed to be a purchase of future receivables, not a loan..
    High risk paper

  3. #3
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    Most a lenders have been doing it already for years

  4. #4
    Karen37a
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    Quote Originally Posted by HDF View Post
    What are your feelings about the Adverse Action notifications now going out from some lenders/funders?

    Will it make doing business more difficult with the A paper folks as they send Adverse Action emails to all declined applicants, or do you welcome them proactively complying with the Equal Credit Opportunity Act and Fair Credit Reporting Act?

    Does encouraging a declined client to have a direct line of communication to the lender/funder (outside of your relationship with them) to investigate the reasons for denial worry you?

    Or, will it serve to help to sell the higher cost funding due to the explicit conforming to laws and offers of transparent reasoning behind denials. While revealing the strictest underwriting approvals as being for the very few? (like when a merchant comes back to you after trying for a bank loan hat-in-hand)

    No matter what, it is a big step in an unknown direction...

    Most people have been getting "adverse action notices" for declined credit on numerous financial products for years. It never deterred the outside brokers.

    People always had the option to walk into a bank on a loan..or choose an independent outside rep, so we are used to it.

    I think the problem lies when people are trying to cover up the fact that they are an "iso" and not a Direct Funder.

    Strong brokers already explained the reason the Funder didn't want them. And the ones who are ethical and used a consultative sales approach already explained what they can do to clean their mess up if they ever wanted to survive.

    The main Key is small or midsize independent Isos or Financial companies finding a niche or way to compete with the big boys until they either become one themselves or make a ton of money retire or die. This has never changed.

  5. #5
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    Quote Originally Posted by MidnightAdvance View Post
    Problem is when funders decline deals due to: “missing daily payments” when this is supposed to be a purchase of future receivables, not a loan..
    Mainly talking about loans at this point. The point is that it can be useful in moving a conversation (sale) forward. A beginning of a conversation and expectations firmly managed by us toward any financing product.

    For instance I will gladly take a quick denial and email to the client sent by Quarterspot, Breakout (starting Thursday BTW) and the rest as an opportunity to sell what IS available. Same thing with SBAs.

  6. #6
    Karen37a
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    Quote Originally Posted by HDF View Post
    Mainly talking about loans at this point. The point is that it can be useful in moving a conversation (sale) forward. A beginning of a conversation and expectations firmly managed by us toward any financing product.

    For instance I will gladly take a quick denial and email to the client sent by Quarterspot, Breakout (starting Thursday BTW) and the rest as an opportunity to sell what IS available. Same thing with SBAs.

    We are being told that the file is denied before the adverse action notice hits the merchants desk.

    Another reason you do not blanket shop out a file

    In fact, some of us with past loan underwriting experience do not have to send a file in...we can calculate/ guess, within a few seconds flat, what the rates will be if approved.

    This is why we know so much about credit algorithms/loan algorithms...to get an edge

    This is also how we knew someone was raising the rates on the backend on us purposefully...we just played stupid, then when we disclosed ...they still didnt understand
    Last edited by Karen37a; 01-23-2018 at 10:06 AM.

  7. #7
    Karen37a
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    If a Funder sends out an adverse action notice via email...instead of regular mail ( which is required). Without notifying you first...

    They are going around you. Id never send a deal again.


    Or they can word it ...blah blah blah ...contact the person you submitted the application to...etc.
    Last edited by Karen37a; 01-23-2018 at 10:48 AM.

  8. #8
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    Breakout email will go directly to business owner, no letter. Qspot emails ISO. Not sure if letters go out.

  9. #9
    Karen37a
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    Quote Originally Posted by HDF View Post
    Breakout email will go directly to business owner, no letter. Qspot emails ISO. Not sure if letters go out.
    I do not know what their internal policies are. If they notify you as well...that's that. Just explain it to the merchant...move on down the line ...A paper B, C, D D minus

    This is why we try to underwrite on our end so we send the right file to the right person.

    This is also why isos/brokers block emails, phone numbers etc on the applications..to .try to slow some funders down from grabbing it from you. And this is the debates on the 7/14 days .And why I say "control the merchant so he goes where you go"

    You cant stand before the evil ogre and yell ...you are the evil ogre. he doesn't care ( not meant for any company/hedge fund in particular )

  10. #10
    Karen37a
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    When you get fed up with it. You will go to 2-3 Funders and stay loyal to those that are loyal to you. Even if they are A or B/C D paper

  11. #11
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    Karen, will you please behave yourself.

  12. #12
    Karen37a
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    Quote Originally Posted by WestCoastFunding View Post
    Karen, will you please behave yourself.
    LOL

    What am I doing? I am just explaining the regulations on credit adverse action and how isos should handle it ( not sure of the newly updated regs)

    What am I supposed to do, its like I am watching a bank heist live.( both ends...purposeful defaults and deals missing )Seriously have some compassion for the poor lil ole brokers who work hard to find the merchants get the file in...they are so excited...they are going to MAKE IT! yeah, get a commission.

    Boooo deal gone someone else funded

    Since you like the series 7 stories so much. I never got in trouble because I thought... I will not be part of stealing some poor schlub in Idahos kids college education on some bs stock and walked out.

    Edit . And I didnt really know if anyone was stealing, i was too young. All i knew is that I had this computer science degree and I thought this company names Microsoft and anothwer name Intel was going to do well...take over the world , so i loaded up on it...diversified into blue chips and bought a little no name called Amazon
    Last edited by Karen37a; 01-23-2018 at 12:43 PM.

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