We had an existing HELOC mature last year in Sep. Since the line was not paid off upon maturity and to aid in collection efforts, we pulled a credit report on the borrowers (husband and wife).

In Oct, the borrowers applied to refinance the HELOC into a HELOAN. When disclosures were prepared, we sent the credit score disclosure notice from Sep. The catch is - when the report was requested in Sep. there was a mix up in the SSN's, so the end result was a credit score for only one of the borrowers (the husband). No one caught it at the time and we did not notice that she did not have a score. Instead, the husband was listed twice and his score was listed twice.

Fast forward to now...we have a compliance audit and it was brought to our attention that we provided a disclosure to the husband, but not the spouse (because of the mix up). This will be a part of his report that our examiners will see when they come for a compliance exam in June.

The auditor said that we wouldn't have to provide a score disclosure anyway if it was not used in the decision. Unfortunately, the scores do appear on the credit approval sheet in the file. They are good scores (over 750), so they did not play a factor.

Since we cannot go back and re-pull a credit report for her as of Sep to get a score disclosure generated, is there really anyway to fix it?

If this is an isolated incident I would notate what happened. What steps will be taken to help eliminate future occurrences and move on to the next opportunity.

If there is a pattern of this happening - training - documentation - sending the affected borrowers a "current" disclosure with a brief explanation - documentation - move on.