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FCRA Credit Report Credit Score Disclosures
Dan Persfull, BOL Guru
Guru Bios
Question: FCRA states "any person who makes or arranges loans and who uses a consumer credit score... shall provide..." the disclosures then defined. If a credit report containing a credit score is obtained, but as a matter of policy, the credit score plays no part in any credit decision are we required to provide these disclosures?
Answer: How can you prove to the examiner that the score played absolutely no role in your credit decision? If you don't use the score, why do you obtain it? FDIC examiners (in the Chicago Region anyways) have stated if the score is present then you must disclose. The key words in your statement are "as matter of policy". It may be your policy, but if the score is present someone is looking at it and you will have a very difficult time convincing your examiner it did not in some way affect the decision.
First published on BankersOnline.com 7/31/06
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