We obtain our credit reports from Company A Credit Services, we ask for reports from three bureaus: Bureau A, Bureau B, and Bureau C. This gives us multiple scores and my understanding of the Final Rule guidance is that we have to have a policy/procedure to choose which score we use. We have decided to use the lowest score for the AAN. So if Bureau A has the lowest score can we only consider information in the Company A Credit Services report that was generated by Bureau A?

Also do we list Company A Credit Services report as the consumer reporting agency since that is who we obtained the report from. Or do we list Bureau A as the consumer reporting agency since Company A Credit Services obtained the information from them?

Finaly, we do not directly use the credit score(number) in our decision making however it is on the report. If we deny someone because of what is contained in that report we should state the score and required info on the AAN correct? On the flip side if we obtain a report but deny the applicant for a reason outside of the credit report we should not state the score and required info on the AAN correct?

Thanks for any help you can provide

If you don't use the scores, then remove them from the reports then all your questions would be moot. You most likely pay more to get them..........

We dont have a credit scoring system but if i was to take the scores off i am sure the loan officers would want them back. That is why i say we dont directly use them.

I would have to opine differently. If the LO's wanted them back then that's a strong indication they "directly" rely on the credit score in their decisions whether they are suppose to or not per policy. Remember, consistently allowing one LO to circumvent your loan policy will in effect change your policy. The examiners will look at your written policy but your consistent pattern and procedures will dictate what your policy actually is.

Your first question I'm not sure what you are asking. If you pulled all 3 bureaus then I would assume you use all information obtained in the credit decision. Which score you choose to report doesn't change that fact.

For the FCRA section you report the name of the CRA you obtained the report from. A reseller is a CRA by definition.

For the AAN section it's not quite as clear. The rules say to disclose the entity that provided the score. I would suggest a conversation with your examiner. FWIW, until I talk to mine next month when they're here I have instructed our people to disclose the CRA that "generated" the score. If TU was the report we used from our reseller TU's information would go in the Reg B AAN credit score section.

If your AA was based on information in the consumer report then you disclose the appropriate information from the report. If the AA is based on something other than information in the consumer report then neither the FCRA AAN or the Reg B AAN credit score section are required.

Thanks Dan,

I appreciate the help

Dan, if I remember correctly, you use Arta Lending. Are you able to get the form to print with your reseller in the FCRA section and then the CRA that generated the score in the AAN section? We are having issues in trying to list the two separate entities.

We don't use their AANs so I can't address this issue.