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Repositories Tighten Physical Inspections Requirements

Effective November 1, 2005 the credit repositories (Experian, Trans Union and Equifax) have significantly tightened the due diligence requirements for all mortgage brokers and lenders desiring access to credit data. While physical inspections have been required for many years, the standards for approval have been increased. These new rules apply to all credit reporting agencies. Key changes include,

  • Inspections now must be completed by independent, third-party inspection firms certified by all three repositories.
  • Each individual net-branch locations must be inspected
  • The new inspection requirements apply to all mortgage brokers and lenders regardless of size, years in business or location.
  • Should a mortgage broker or lender change location, a physical inspection is required on the new location.

Key components of the physical inspection include,

  1. Physical security - Business is located at address provided and space is indicative of types of products / services marketed
  2. No evidence of any of non-permitted activities such as credit repair including a review of web sites, phone numbers and advertising
  3. Verification of licensing (if applicable)
  4. Security - Physical security mechanisms, practices for securing and disposing of confidential information (i.e. shredder on site, lockable files, computers password secured with non-stored passwords.) 
  5. Photographs - Digital photographs of interior and exterior of business including permanently affixed signage.

For those operating from a residential address, in addition to the above requirements, the work space must be separate and secure from living space (e.g. office with lockable door.) Experian also requires those operating from a residence be re-inspected annually.

All end users are also subject to ongoing repository compliance audits. These audits are designed to insure consumer information is obtained and used by the subscriber for the permissible purpose indicated (i.e. Mortgage.) This includes the use of "secret-shopper' programs to detect those engaged in prohibited activities such as credit repair. Should you be audited by one of the repositories, you will be required to provide at least one of the following,

  1. Original credit application or mortgage/HUD form 1003
  2. Detailed loan officer notes
  3. Screen-shots containing information regarding the applicant.

Should a broker or lender fail to meet the minimum physical inspection requirements, or during an audit, fail to provide the required documentation, the repository has the option of terminating access to credit data. Should that occur, you would be prohibited access to credit data through any credit reporting agency.

Please remember, these requirements are established directly by Experian, Equifax and Trans Union. Credit Technologies has no discretion in the application of these requirements. For questions regarding this subject, or any Credit Technologies product or service, please contact us toll-free at 800.445.4922 or via e-mail.

Thank you for considering Credit Technologies, we look forward to helping you close more loans.

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