As far as collecting information goes, are you saying that it’s okay for a creditor to restrict consumers from providing all six pieces to allow time to collect additional information?

That’s something the bureau has given guidance about; that would not be permitted under the bureau’s informal guidance. The bureau has said lenders cannot prevent consumers from giving them information or refuse information from consumers until they get all six items. For example, you can’t tell a consumer, “You’re not allowed to submit anything else to me until I get your assets.” That would be requiring additional information, essentially bringing back the seventh “catch all” item, and would be a violation of the rule.

Answered By: Richard Horn