I've been reading the other posts, but would like clarification on this. Our credit bureau will provide us with the H3 Real Estate notice. Do we still send out the old "Notice to Home Loan Applicant" or does this new notice replace it?

I think maybe I found my answer. It doesn't look like it is still required because of it being a part of the new disclosure.

That's right, it's been combined. The NTHLA form is still valid, however, if it applies in an instance where RBP would not.

Ok, thanks.

If you are giving exception notices and not the RBP notices, (and you have contracted with your credit bureau provider to mail the notices), is there an instance i'm not aware of where a free-standing NTHLA would be required? I'm struggling to think of one and am wondering if i'm missing something.

Perhaps if your loans are not risk base priced?

Would a free-standing NTHLA still be required when the loan is denied? I know adverse actions are one of the exceptions where the CSD or RPB wouldn't be required, but don't we still have to comply with section 609(g) and give the NTHLA?

Would the exception notice, which includes the NTHLA, suffice as giving the NTHLA itself in the case of an adverse action? Would make no sense to me that you would have to give the NTHLA as a stand-alone item when you could just give it as part of your exception notice.

raitch..that's what we intend to do for products that are RBP, but denied.

Go ahead and give the exception notice Joker? Is that what you mean?