Since it appears FIS is leaving this up to us to decide, what are others thinking??

We only use the qualifile score to determine if an account qualifies to be opened. It is not used in any loan decision (ODP, etc). I'm leaning toward not providing the credit score disclosure short of getting a legal opinion or until more guidance comes out from the examiners.

Thoughts??

IMO if used in a lending decision, then yes.

If rejecting the opening of a deposit account, you would still need to provide the FCRA adverse action that you should already be providing.

Since we use it only to reject the opening of a deposit account itself, we would still only provide the FCRA adverse action (not providing the 'credit score' disclosure).

Yep we are going to continue giving the AA notice as we have in the past but not include the new credit score disclosure.

No No No....

Either the Qualifile is a credit score as defined by the FCRA or it isn't.

What you use it for does not matter.

If it is a credit score under the FCRA, for a deposit product or credit product, a denial will trigger the credit score AAN disclosures.

Sorry, but how many times does this need to be said??????

I'm wondering how bankers are defining the credit score issue because FIS won't do it for us.

I get what your saying, but I don't think you can ignore how its used when you are applying the definition of a credit score.

I'm saying that I am not going to define qualifile as a credit score...part of how I arrived at that conclusion is based on how I used it because I believe that is pertinent to the definition of a credit score.

If you review the issuance by the FRB on the new credit score disclosure, you will see that they specifically state that use of a credit score is covered by this new disclosure if used for any purpose including loans, deposit accounts, insurance and employment.

The key is if it is a credit score, not how it is used.

From p. 17: "The Board believes that a person would need to disclose a credit score obtained from a consumer reporting agency as part of the adverse action notice as set forth in section 1100F of the Dodd Frank Act, even if the person used the credit score to take adverse action for a non-lending product. In requiring credit score disclosures, section 1100F does not state that the credit score disclosures are only required for adverse action decisions related to credit."

And including the introduction to the cite provided by raitchjay gives even more information.

"Section 202.2(c) of the ECOA limits the definition of adverse action to decisions regarding credit. The FCRA, however, does not include such a limitation. See section 603(k)(1) of the FCRA. The FCRA therefore applies to adverse action decisions related to credit, but also decisions regarding, for example, a deposit account, insurance product, or employment. Although a credit score may generally be used in making or arranging loans, a credit score may also be used in taking adverse action not related to credit. The Board believes that a person would need to disclose a credit score obtained from a consumer reporting agency as part of the adverse action notice as set forth in section 1100F of the Dodd Frank Act, even if the person used the credit score to take adverse action for a non-lending product. In requiring credit score disclosures, section 1100F does not state that the credit score disclosures are only required for adverse action decisions related to credit."

I have to say, it does seem a little incongruous in one aspect to me: it doesn't seem to matter how or if you "use" the credit score for deposit products; if there's a score, you used it and you need to disclose it. On the loan side though, you can get a credit score, but if your reason for denial is totally non-credit based, it would seem not only that you wouldn't have to give the credit score, but that you would be non-compliant to do so. I'm more on the lending side, so maybe i don't have a great understanding of how the deposit side might work....that is, the existence of a score might be representative of factors that would automatically lead to the denial of those accounts, in which case, it would be a moot point i guess.

If you obtain a score that is determined to be a credit score (the key factor here) and do not use it - whether for a loan, a deposit account, employment, etc. - you have to make the same argument as to how that score was not part of your decision.

If you do not consider the score, it is easier either to just disclose it or do not get it in the first place.

My background is lending and not deposits. Our current ChexSystem reports do not provide a Qualifile number. Is this something that there are different levels that banks can pay for? I would like to understand why some banks are getting these numbers and my bank is not. I don't want examiners to come in and somehow hammer us on this.

It does depend upon what the bank purchases.

Kathleen, i'm speaking of instances where your denial reason is something that is indisputably not coming from the credit report (collateral value for instance). In that instance, not only do you not have to give the credit score, i believe it is non-compliant to do so. I guess i'm wondering if that applies at all to the deposit side (i'm thinking probably not, as there are no equivalents to "lack of collateral value" that i can think of for the deposit side).

We don't get the Qualifile score either and a poster informed me the other day that it is something that can be removed or hidden at the bank's request.

I agree. If you decline to open a deposit account because you cannot verify identity, this disclosure would not be required because a score has nothing to do with the reason for the decline.

Thanks for the confirmation Kathleen.

Does it matter that the Qualifile product we use only pulls information from debit bureaus to create the score? It does not pull in information related to credit history.

"Debit" bureaus are Credit Reporting Agencies under the FCRA. Deposit account history is an element considered by many lenders in evaluations of creditworthiness.

You can send a request to FIS to suppress the score at no charge. Send your email to CARSupport@fisglobal.com and provide your institution number and request that the Qualifile Score be suppressed. I did that and verified today that the score is no longer included in our report. That way you wont have to worry about that part at least! We werent using that score in any way so suppression seemed the best option for us.

If we had the score suppressed but it was still factored into the decision that's returned to us from FIS, wouldn't we still have to disclose it?

If you have the score suppessed, there is no score to disclose. Some banks do this on the credit side.

My two cents - the way I understand it, FIS can set you up so that the score isn't "displayed" but that doesn't necessarily mean it isn't "used". If they are giving you an accept, decline, review recommendation back and you've set up strategy based on score with them, then the score is still being considered - they're just not showing it to you.

I'd be cautious about assuming that if you supress it from view that you're o.k.

What's really funny (sad, really), is that in the user documentation they define the Qualifile Score as a number from 100 to 899 that is the result of a predictive risk model analyzing a combination of ChexSystems data, DebitBureau data and credit data (Premier and Customer Premier only).

The then define a Credit Score as being for Premier and Custom Premier products only, with accompanying reason codes being returned from the Credit Bureau used by your institution.

From this I infer that if you are using the Qualifile Score, and are not a Premier or Custom Premier user, it is NOT a credit score.

Doug,

I totally agree and that is what I was trying to say in my earlier post. We use QualiFile; however, we do not use the Premier or Customer Premier option which accesses data from the consumer's credit report.