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#1610703 - 09/29/11 05:59 PM 3 scores on NHLA?
Funky Falcon Offline
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Joined: Jan 2008
Posts: 242
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
Joined: Aug 2002
Posts: 72
Hey Funky,

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


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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: 47,358
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.
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: 602
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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