[April]

If a customer is inquiring about a Mortgage Loan and we use the tier pricing when can we pull the Credit Bureau? Do we need to wait until we have a completed application that triggers the Loan Estimate or can we pull the bureau and submit application later?

[rcooper]

If a customer is simply wanting pricing information can’t you provide the range of rates and associated pricing without pulling a credit report? I would be hesitant to pull a credit report for someone requesting rate information.

FCRA says as long as you have a legitimate business purpose you may pull a credit report. Look to 604.a(3). It sounds like this might be a verbal application or prequalification/preapproval request. You may need to review your bank’s policy/procedures to determine when you are permitted to pull credit reports. Also, review your contract with the CRA determine what it allows. If you don’t have something in writing (application or permission from consumer) you need to document when you received the request from the consumer and why it constitutes a legitimate business purpose. Also, there may be situations when an AAN would need to be sent. All of this will need to be tracked and documented – you need to determine if your financial institution has controls in place to do this outside of your normal application process.

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