If you don't pull or use the credit score to make the decision then you will still use the new model forms. You just won't check the credit score paragraph nor complete that section of Part II. Not sure off the top fo my head what/if the penalty is for continuing to use the old forms.

Model C-1 - deleting the optional information regarding the credit score.

Thanks Randy that's the one I had picked.

I have done a couple of searches online to see the publication of this in the federal register but haven't been able to pinpoint it. Does anyone have that link?

Never mind, I just found it. Thanks

We have sometimes a credit report with no credit score but the report is filled with collection accounts. I think there are key factors listed but no credit score because there is no credit history.
We would deny based on collections. - With no credit score would we leave that area blank and list the key factors or would we not put anything? Thanks

Dealing with "no score" is discussed in the FRB guidance, in the analysis section. It is very important to review the entire issuance.

"Disclosure that no credit score is available.

In some cases, a creditor may try to obtain a credit score for an applicant, but the applicant may have insufficient credit history for the consumer reporting agency to generate a credit score. One commenter asked that the creditor have the option to provide the applicant notice that no credit score was available from a consumer reporting agency in the space available for the credit information disclosure.

Section 1100F only applies when a creditor uses a credit score in taking adverse action. The creditor cannot disclose credit score information if an applicant has no credit score. Nothing in section 1100F of the Dodd-Frank Act prevents a creditor, however, from providing the applicant notice that no credit score was available from a consumer reporting agency, although section 1100F does not require such notice."

Thanks Kathleen- I appreciate it. I'll read it again.