I noticed the exception notice provided to us from the credit bureau is the H-4. I called and was told that is the one provided by the bureaus. So how are people doing the H-3? My contact seemed unaware of the different forms?? Suggestions? Am I missing something?

2. When pulling three reports for a secondary market RE loan how are you disclosing the forms? Three forms - one from each bureau? I don't see a merged exception notice - true?

3. Just making sure....the old FCRA2 (NTHLA) is a duplicate of the H-3, right? Anyone providing both forms or just the new H-3?

Thanks!

I guess my question for #1 and #2 - is this a credit bureau reporting issue? We use Microbilt. Those of you that use Microbilt are you getting what you need?

It appears other lenders that use other vendors are getting the correct docs.

PHC -- You're correct; for RE-secured transactions, you need to be using model form H-3 rather than H-4. Don't know anything about Microbilt, but it sounds like they're the ones who are missing something, not you. You need to get with them right away and let them know you're using their credit reports in connection with RE-secured transactions and that you need to start getting model form H-3 yesterday.

If you have both an RE lending group and a consumer lending group pulling from the same vendor, then you need to set up different customer codes or something so the RE folks get form H-3 and the consumer people get form H-4. Could that be what happened here?

And yes, model form H-3 replaces the old NTHLA required by FCRA section 609(g). That's why the majority of lenders appear to have gone with the exception notice alternative -- H-3 kills two birds with one stone.

Good luck out there.

Ooops, forgot your second question on multiple reports/scores. The supplementary info at 75 FR 2743 says that if you pull multiple credit scores, you should disclose the score you actually use (e.g., the middle score, the most recent score, whatever your procedure is). If you use an average of all three scores (i.e., the number you use doesn't match any of the customer's actual scores), you would disclose one of the actual scores you obtained. Your choice. At the lender's option, you can include more than one score, but I can't think of a reason why anyone would choose to do that.

PHC,

What CB do you use and are you pulling a trimerged?

We pull all reports thru Microbilt.

If I do a car loan or other I pull only Transunion - which is fine since H-4 is produced and given and all is good.

If I do a RE loan we pull a merged report from all three CBs and use the middle score (so it sounds like I would do the form for the middle score bureau). Unfortunately when I called the vendor they were unaware of different forms for RE vs. non and that concerns me - I can't be the only one???

And thank Way Out West...helpful!
I don't want to continue to manually entering the FCRA9 (H-3) as I have been...sigh