Tag: soft pull

FHA- Credit Pulls Prior to Closing: Does FHA require a credit refresh or a soft pull at the end to be sure he hasn’t incurred any new debts?

Answer: FHA does not have a requirement to re-pull credit automatically right before closing, but they do require it when there are inconsistencies between any information in the mortgage file and the original credit report. That said, you may want to discuss this situation with your management regarding your company procedures, as some lenders may […]

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Compliance – Soft Pull vs. Hard Pull: Recently, our originators are requesting the ability to pull a soft pull on a client vs. a hard pull, as other lenders in the area are doing it, and it could be a cost-saving measure. Is this a regulatory issue?

Answer: QM/ATR only requires that the lender determine how they are going to validate credit history vs. telling you what type of report that you need. However, it will likely cause you regulatory issues under ECOA. When you issue adverse actions based solely on a soft pull, you do not have the entire picture of […]

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