The MLO compares the file facts with FCRA Credit Score Disclosure during an underwriting condition review. Which conclusion is accurate?
Correct Answer
A) Use the report only for a permissible credit purpose
Why this is correct: The Fair Credit Reporting Act (FCRA) and its implementing Regulation V strictly govern the use of consumer reports, including credit scores. The core principle is that a consumer report can only be obtained and used for a "permissible purpose" as defined by law, such as a credit transaction initiated by the consumer. The MLO's duty during an underwriting review is to ensure the credit report is used solely for the legitimate purpose of evaluating the applicant's creditworthiness for the mortgage. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because internal policies cannot override federal FCRA requirements for permissible purpose and proper disclosure. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because compliance with FCRA is mandatory at the time of use, not contingent on a regulatory inquiry. "Resolve the FCRA Credit Score Disclosure issue with the credit underwriting exception that does not fit the facts" is wrong because applying an exception that doesn't match the situation is improper and does not correct the underlying FCRA compliance failure. Exam tip: Remember the FCRA's central rule: no permissible purpose, no access. Your permissible purpose is typically the consumer's application for credit.
Why This Is the Correct Answer
The correct response is "Use the report only for a permissible credit purpose" because Consumer reports require a permissible purpose and proper FCRA/Reg V handling.
Why the Other Options Are Wrong
Option B: Use an internal exception instead of the required federal disclosure or timing rule.
Use an internal exception instead of the required federal disclosure or timing rule. is not correct because it does not apply the rule tested by this file scenario.
Option C: Wait until a regulator asks for the file before applying the federal requirement.
Wait until a regulator asks for the file before applying the federal requirement. is not correct because it does not apply the rule tested by this file scenario.
Option D: Resolve the FCRA Credit Score Disclosure issue with the credit underwriting exception that does not fit the facts.
This distractor shifts the issue to a different trigger, product, or timing rule instead of applying the rule tested in the stem.
Memory Technique
FCRA credit-reporting rules: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.
Exam Tip
Match the file facts to FCRA credit-reporting rules; do not choose an exception or shortcut that skips the required rule.
Common Mistakes to Avoid
- -Choosing an internal exception instead of the governing rule
- -Treating preliminary or informal facts as a substitute for required documentation
- -Answering from a familiar but unrelated mortgage topic
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