Under section 764.51 (b)(8). it states that "if it is necessary to verify debt, debts will be verified through the credit bureau reporting system". I believe that this should include that the debt can be verifed through the credit bureau reporting system or any other suitable method to verify the debt owed by the applicant. Why? Because most of the farm creditors do not report the debts that are owed to them to credit bureaus and that information does not show up on the reports when they are pulled. For example, John Deeere Credit, as a rule does not report their debt to credit bureau's and the debt may be substantial. If we can't require the applicant to submit other forms of debt verification, how do we know how much the applicants owe and what their payments are? This information is needed to detrmine if the cash flow plan is even feasible. I understand that these are to be streamlined loans but we still need to verify the debts that an applicants owes....
Comment on FR Doc # 2012-12685
This is comment on Proposed Rule
Microloan Operating Loans
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