Results 1 to 25 of 57
Hybrid View
-
01-27-2016, 12:45 PM #1
- Join Date
- May 2015
- Posts
- 14
Adverse Action Notices?
So what exactly do you disclose when giving adverse action notices? The Equal Credit Opportunity Act requires specific reasons for denial and in official staff interpretations, they go into detail as to what needs to be disclosed when using credit scoring systems:
4. Credit scoring system. If a creditor bases the denial or other adverse action on a credit scoring system, the reasons disclosed must relate only to those factors actually scored in the system. Moreover, no factor that was a principal reason for adverse action may be excluded from disclosure. The creditor must disclose the actual reasons for denial (for example, “age of automobile”) even if the relationship of that factor to predicting creditworthiness may not be clear to the applicant.
5. Credit scoring—method for selecting reasons. The regulation does not require that any one method be used for selecting reasons for a credit denial or other adverse action that is based on a credit scoring system. Various methods will meet the requirements of the regulation. One method is to identify the factors for which the applicant's score fell furthest below the average score for each of those factors achieved by applicants whose total score was at or slightly above the minimum passing score. Another method is to identify the factors for which the applicant's score fell furthest below the average score for each of those factors achieved by all applicants. These average scores could be calculated during the development or use of the system. Any other method that produces results substantially similar to either of these methods is also acceptable under the regulation.
-
01-27-2016, 02:56 PM #2
- Join Date
- Nov 2014
- Posts
- 438
What is disclose in an adverse action letter is between the borrower and the lender. If you have ever seen an adverse action letter, you know it shows a few comments from information gathered by the credit reporting agencies where credit was pulled.
LoanMe has over 150 loan agents taking an average of 15-20 applications per day. Internal scoring and the algorithm used to assess a pre-qualification decline are not something that agents are given access to. This is done for the privacy and protection of the borrower applying for a LoanMe loan.LoanMe Business
949-535-7798
Email: Business.Loans@LoanMe.com
www.loanme.com/SBL-partner
1900 S State College Blvd. Suite 300
Anaheim, CA 92806
-
01-27-2016, 03:55 PM #3
- Join Date
- May 2015
- Posts
- 14
You are referring to an FCRA Adverse Action, which only must be provided to a consumer applicant. They are not required for business credit because the commercial entity is the applicant, the consumer is a guarantor and does not meet the definition of an applicant.
An ECOA or Reg B adverse action notice is required for business credit and the notice must contain "either a statement of the specific reasons for the action taken or a disclosure of the applicant’s right to a statement of specific reasons and the name, address, and telephone number of the person or office from which this information can be obtained"Last edited by jfranz17; 02-02-2016 at 02:25 PM. Reason: correction
-
01-27-2016, 04:14 PM #4
- Join Date
- Nov 2014
- Posts
- 438
Privacy is of the utmost concern for LoanMe on both consumer and business information. I'm not sure you understand how our lead referral and application process (initial pre-qual, initial declines, UW declines, etc.) works, and how we are able to abide by the laws for consumer and business loans. If you would like to give us a call directly we would be more than happy to discuss them with you. We can be reached at any of the numbers listed in our signature below.
LoanMe Business
949-535-7798
Email: Business.Loans@LoanMe.com
www.loanme.com/SBL-partner
1900 S State College Blvd. Suite 300
Anaheim, CA 92806
-
01-27-2016, 09:39 PM #5
- Join Date
- May 2015
- Posts
- 14
-
01-27-2016, 10:18 PM #6
- Join Date
- Jul 2014
- Posts
- 1,746
-
01-28-2016, 06:27 AM #7
- Join Date
- May 2015
- Posts
- 14
Yes
Last edited by jfranz17; 02-02-2016 at 02:27 PM. Reason: edit
Similar Threads
-
Which Lender is doing Monthly besides LoanMe
By JoePat in forum Deal BinReplies: 5Last Post: 12-10-2015, 12:20 PM -
LoanMe, OK! Who Else with no Min. FICO Requirement?
By Fundyman in forum Business LoansReplies: 14Last Post: 11-14-2015, 12:20 AM -
Looking for a contact at LoanMe
By CREDITEXPRESSDIRECTSF in forum Merchant Cash AdvanceReplies: 12Last Post: 11-02-2015, 01:43 PM -
Co-working Space Available for Funders
By PMF in forum Help WantedReplies: 0Last Post: 06-18-2015, 02:38 PM -
Free office space in Ridgewood NJ
By halasniks in forum Everything elseReplies: 3Last Post: 06-03-2014, 11:04 PM