[biancacrook]

We offer consumer customers the options to apply as individual with use of separate income as a source of repayment (i.e. spouse income). If a customer chooses this option do you soley rely on the customer’s application to figure the debt of the other person or do you pull credit to ensure the DTI is figured correctly?

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[rcooper]

From the information you’ve given it doesn’t sound like you have a permissible purpose to pull a credit report on the spouse since they won’t have any connection to the transaction (e.g. co-signor, co-applicant, etc). Look at the FCRA section 604 for permissible purposes. Section 604(c)(1) gives information on pulling a credit report for transactions not initiated by the customer – basically, it has to consist of a firm offer of credit (prescreen/solicitation of credit). Section 604(a) gives the general permissible purposes. 604(a)(3)(A) or (F) is your permissible purpose for you applicant, but it wouldn’t cover the non-applicant spouse.

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