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Can you please clarify the exceptions to force-placed insurace in 1024.37(a)(2)? It is my understanding the first exception is for flood insuracne; howerver I am extremely confused about the other two exceptions.
Also, am I correct these transactions only cover consumer credit transactions covered under RESPA? Thank you so much for your help.
In looking the FCRA accuracy and integrity rules, under the duties upon notice of dispute, when the investigation is complete, the results are to be reported to CRA’s to which we furnish information. If we receive that credit dispute from CRA, are we required to report our findings back to the CRA and the consumer or just CRA?
Under 1022.43 for direct disputes we report the results of our findings to the consumer and CRA if necessary.
Thanks for your help. Have a great day.
No this is not a HELOC. We already offer this product which, for us, has different characteristics. Our bank does not report HELOCs on the LAR. For purposes of reporting this home improvement Note on the LAR, would it help clarify the temporary financing definition if language on the Deed of Trust and Note both indicated this product was for temporarY financing and can not be renewed, refinanced, or modified in any way.
Along the same lines, I am trying to find guidance concerning when an individual has entered into bankruptcy. It is my understanding, even though an individual enters bankruptcy, the institution is still required to accurately report information to the consumer reporting agency. However, I am having trouble finding documentation to support this. I am trying to encompass bankruptcy situations in my accuracy and integrity procedues. Any help would be greatly appreciated. Thanks.
