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01-29-2015, 03:15 PM #1
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Of course, no doubt! It is a two-way street and I do not expect any special treatment. I am talking about existing relationships where we have established credibility. I wouldn't expect a brand new partner to make special exceptions(like us pulling the FICO score).
As far as competing on a file, I have to disagree; I wouldn't do something underhanded like send something out once an offer has been made and accepted verbally. Ever. I would, however, send it out to 2-4 Lenders simultaneously after I initially receive it and see who puts their best foot forward. It is a competitive business. I am competing with other ISOs/Direct Lenders on files and I accept that. It comes with the territory. The way i see it is our interests are aligned, the Lender,the Merchant, and myself. Lender wants Merchants to add to their portfolio, the Merchants want/need the best offer/term for the money they are receiving and we need the two to come together. Until the day i get psychic powers, all I can do is narrow that part down to a few Lenders. I hope at some point in the very near future I only have to use 4-5 total Lenders and know their Underwriting methodology as if it was my own. Communication on both sides makes that a lot more possible.
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01-29-2015, 03:48 PM #2
I think you said at the end is the key. Understanding different banks underwriting process and then deciding what works best with your process of selling a deal is when the whole process gets easier. Most banks give you a pretty clear picture of what deals work best for them. Having that info and using it to get the right deals to the right banks will streamline things and make funding deals easier and reduce the number of credit pulls because you will know what deals belong at each bank
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01-29-2015, 05:04 PM #3
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This would (arguably) make people doing this a consumer reporting agency under FCRA. A consumer reporting agency is defined by FCRA as follows:
"(f) The term “consumer reporting agency” means any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties, and which uses any means or facility of interstate commerce for the purpose of preparing or furnishing consumer reports.
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01-29-2015, 05:58 PM #4
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01-29-2015, 06:11 PM #5
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Pulling someones credit report to use for a private, consumer or business transaction doesn't require any licensing. Pulling someone's credit and then furnishing that information to a third party, especially when also accompanied by bank statements and other financial documents to be used in making a credit decision, is where the Feds might say that you are a CRA as defined by FCRA.
"regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties"
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01-29-2015, 08:47 PM #6
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