To comply with Experian, Trans Union, and Equifax, we must be able to track all secondary usage and report to the bureaus. CIC has gotten the cooperation from our software provider to track and report secondary usage to the bureaus to stay in compliance. There will be an additional line item on the bill to reflect the charges brought on by the secondary usage from each bureau. Transunion has recently defined a position on secondary use it is the file fee itself CIC will pass along the file fee charge as reflected below.

As we address these issues daily, we are seeing the repositories change their interpretation of these FCRA guidelines. We are happy to answer any questions you may have along with giving you any updates we receive.

Thank you for the business.

Sincerely,

Eric Wimsatt
Sales Manager

Michael Thomas
Operations Manager

Secondary Use Frequently Asked Questions

Effective March 1st, 2007, Trans Union, Equifax, and Experian enforced the reporting of “Secondary Use”.

Q: What is a Secondary Use?

A: Secondary Use refers to the process whereby a credit report is ordered by one lending entity and then Forwarded to another or multiple entities as part of the lending process. Examples include:

• Mortgage brokers who order a credit report and then deliver a copy of that report to a Wholesale lender.
• Lenders who order a credit report and then request a copy of that report be sent to Desktop Underwriter or LP.com.

Secondary Use occurs when a lender or broker provides all or any portion of the consumer credit information contained in a merged or single credit report to an entity other than the end-user for which the credit report was originally prepared. This includes, but is not limited to sharing consumer credit information provided in view-only format, electronic transmission of the report (e.g., electronic reissue) or a paper copy.

Q: Why was the Secondary Use policy created by the Credit Bureaus?

A: These policies were created to address FCRA compliance, data security, data accuracy and to provide consumers with a means of knowing which entities are reviewing their personal credit.

Q: What is Re-use (and/or Reprint) of a credit report?

A: Re-use (and/or reprint) is different from Secondary Use. Re-use occurs when the credit report information is re-used for the same permissible purpose by the same end-user that requested the original report. Examples include:

• Lenders who order a credit report and then request a copy of that report be sent to their inhouse LOS or in-house processing/underwriting center. (same end-user)
• Lenders who order a credit report and then re-use it for internal auditing purposes on the consumer approved loan. (same end-user)

Q: How will inquiries associated with Secondary Use affect a consumer’s credit profile?

A: The repositories will post each Secondary Use inquiry as a “soft inquiry.” Soft inquiries are only visible to the consumer when they request a copy of their report from the repositories. It is important to note that soft inquiries have no impact on a consumer’s credit score.

Q: What are the new Secondary Use fees and when will they become effective?

A: CIC Mortgage Credit, Inc. will begin charging for the secondary use of credit reports beginning April 1st, 2007. Please call CIC for current reuse prices as we adjust them according to the current fee from the Credit Bureau's as they adjust prices to help our clients with cost.

Note: The Secondary Use fee is in addition to your standard electronic reissue fee.

Q: Is there a way to avoid multiple Secondary Use charges? I sometimes send a credit report to many different lenders:

A: If you are submitting a consumer’s file to multiple lenders you cannot avoid multiple Secondary Use charges. The process requires that each lender be recognized as a Secondary User via the soft inquiry process, meaning that you will be charged for each instance of secondary use.