Decision block 01
Key service note
Do not use generic “soft check only” language
The authorization should identify the real parties and scope permitted by the live integration. If a hard inquiry can occur, the page and form should not imply otherwise.
Decision block 02
What an authorization can cover
- Obtaining a consumer report from one or more consumer-reporting companies.
- Using consumer-report or verification information to evaluate identity, fraud risk, eligibility or creditworthiness.
- Rechecking or refreshing information during a request where permitted by the consent and applicable law.
- Sharing the submitted request with participating partners that may use their own authorization process.
Decision block 03
CTC request vs lender credit decision
StageResponsibility
CTCLoans requestRoutes information under the service model and the consents presented.
Partner screeningMay involve identity, bank, income or consumer-report checks depending on the partner.
Lender decisionThe creditor applies its own criteria and is responsible for its credit decision and required notices.
Hard inquiryMay occur when a lender or other authorized party accesses a report for a credit application under its process.
Decision block 04
What the live consent should make clear
- Who may obtain the report or verification data.
- Why the information may be obtained.
- Whether the inquiry may be a hard inquiry.
- Which request or service the authorization applies to.
- How the authorization relates to participating partners.
- How to contact CTCLoans for service/privacy questions and the partner for its own credit process.
Decision block 05
Your consumer-report rights
- You can review consumer-report information and dispute inaccurate or incomplete information with the reporting company and information furnisher as applicable.
- If a creditor takes adverse action based on consumer-report information, federal notice requirements can apply.
- CTCLoans should not generate a formal lender denial reason unless that reason came from the creditor responsible for the decision.