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#1610703 - 09/29/11 05:59 PM 3 scores on NHLA?
Funky Falcon Offline
100 Club
Joined: Jan 2008
Posts: 242
Minnesota
Can we still disclose 3 credit scores on the Notice to Home Loan Applicant if we pull a tri-merge credit report? Our loan document vendor is saying that the Reg. changed and you can only disclose one score as of 1/1/11.

I don't see anything in FCRA 609(g)(1)(D) that says you have to use only ONE score.

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#1622568 - 11/01/11 02:09 PM Re: 3 scores on NHLA? Funky Falcon
deeb Offline
Member
Joined: Aug 2002
Posts: 72
MI
Hey Funky,

Did you figure this out? I would be interested to.
_________________________
Dee

CAMS, CRCM

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#1622847 - 11/01/11 06:09 PM Re: 3 scores on NHLA? deeb
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,765
Bloomington, IN
The 609(g) rule did not change but under the RBP rules you are allowed to substitute the H-3 exception notice for the NHLA requirements. On the RBP exception notices you only disclose one score.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1623261 - 11/02/11 02:17 PM Re: 3 scores on NHLA? Dan Persfull
JobSecurity Offline
Platinum Poster
Joined: Oct 2009
Posts: 579
Talking about tri-merge....under ECO published 7/15/11, pg 41597 says "expects that creditors will have policies and procedures to determine which of the multiple credit scores was used in taking adverse action." I would assume examiners will be looking for this.

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