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:
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