Negative Information Disclosure

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• September 9, 2011 at 12:29 pm EDT #2420
  compliance4ever

  Member

  I seem to have a brain block on the Negative Information Disclosure. Is the negative information disclosure required on commercial loans, when the borrower is a business and the co-borrower is an individual? Our loan platform states it is required on transactions made for personal, family or household purposes. However part of the reg says it is required when you report a customer’s information to a CRA. We report on businesses; therefore, that’s where I am coming from that they need the notice. Am I totally crazy? 😕

  September 14, 2011 at 11:17 pm EDT #2768
  JGo9

  Participant

  If you would normally report them to a CRA then I do believe that you would need to give them that disclosure.

  Remember that you can give that disclosure at closing if you wanted to cover yourself.

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