If no credit is pulled is there a New Adverse Action form for that type of turndown?

You only have to complete the credit score section if a score was used for the denial.

Forms C-2 through C-5 contain only the section 615(a) disclosure (that a creditor obtained information from a consumer reporting agency that was considered in the credit decision and, as applicable, a credit score used in taking adverse action along with related information).

So we use the "old" ones for when credit wasn't pulled and the credit score wasn't used?

Can we use the new Adverse Action and just leave the "Credit Score" section blank? That way we have one form that we use, it's just a matter of if the credit score disclosure section needs to be complete or not....

Raises a similar question....applicant has no credit score. Leave that section of the A?A blank???

Page 7 of the final rule:

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.