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Episode 10: Borrower cross-qualifications that break the law - with Jerra Ryan (part 1)

November 7, 2017

Cross-Qualification = when the listing agent demands that your loan officer send a borrower's personal financial information, credit report and/or AUS findings to a competing lender prior to submitting an offer...or something like that.

 

Just so you know, the practice may violate GLBA and the lender's own privacy policy. It may violate the lender's contracts with the GSEs. It is also very likely that an underwriting decision is taking place, invoking disclosure requirements that aren't being complied with under TRID, TILA, RESPA, required reporting that isn't taking place under HMDA and treatment/disclosures not happening under ECOA if the loan is not approved. And we haven't even touched state law violations yet.

 

Why is this even happening? Is there a legal way to do this? Find out by listening to Jerra in this two-part series.

 

 

 

 

  

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