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I’m looking for suggestions on how to “teach an old dog a new trick”.
At issue – credit reports and applications. I’m trying to get lenders to document any occasion in which a credit report is going to be dated prior to the date that is on an application for credit. IMO, at the heart of FCRA, a permissible purpose is all that’s required to obtain a credit report and a permissible purpose can be the result of a customer saying, “I’d like to buy a car, can you tell me how much I can borrow?” It’s easy to say that a lender should complete (or start or date) the credit application on that date, but that’s not always going to happen and all sorts of things happen in between. However, I’ve requested that the lending staff document the mismatches in order to keep files neat.
A seasoned lender remembers the good old days very fondly and reminisces to me, “I can pull a credit report on an existing customer, can’t I?”. 604(a)(3)(A) discusses review, collection, and credit extensions. The lender could argue that he wants to “review” the account, but why does he want to review the account? Because they have a credit request.
Here’s the deal. How do you go about a tactful way of instituting change when the persons who need to change are firmly entrenched in their opinions and have been in their positions so long that they have accumulated so much goodwill (clout) that you have to tread lightly with them.
Sorry for rambling, just a bit frustrated.
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