Reusing a Credit Report
Reusing a credit report for a subsequent transaction has, historically, been a pretty common lending practice. While we see fewer institutions doing this each year, there are still some out there. Often the details are spelled out in an institution’s loan policy, for example, it might state how old a credit report can be to reuse it. Over time, however, regulatory requirements have changed and evolved and, as a result, we believe the current regulatory environment does not support the reuse of credit reports. Whether you agree or disagree, it’s clear that reusing credit reports can increase the potential risk for compliance violations. Some areas to consider include:
- Fair Credit Reporting Act
- Truth in Lending (Ability to Repay)
- Military Lending Act
- FACT Act (Credit Scores & Fraud Alerts)
- Contract Issues
The November 2016 issue of our magazine, Banking on BCC, included an article outlining our position. We recently made this article available in the Free Lending Tools on our website.
Published 2026/02/17
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!