Even though you do not use risk based pricing. If you check credit and deny the loan in whole or in part based on the information contained on the credit report, you have to disclose the score used for the denial and as many as 4/5 reasons supporting the denial...
I disagree. The revisions to Reg B only require you to include the credit score and related factors on the AAN if you obtain use the score
in your decision (unlike the RBP rules which only require your to use the report). However, if you are not risk-based pricing your loans, as stated in your original post, then why pull a score at all? If all approved applicants are offered the same credit terms you are exempt from the RBP and exception notice rules, so why obtain the score?
My opinion- if you are pulling a score you will have a rough time defending your position that you are not "using" the score since the new definition in the final rule for "using" a score is pretty broad.
Aside from the disparities in the regulations, we use Arta for denials and their new form (which it sounds like you are using as well)does not allow you to disclose that you used a credit report but not a score; if you check the box for one it automatically checks the boxes for both. Hopefully that is something they will correct with an update.