In regards to employment applications and adverse action notices, adverse action could occur due to negative credit history, but we don't base our hiring decision on the applicant's credit score.

1. Do we need to use the new form under this circumstance?
2. We have the option to receive the applicant's credit score or not, but we don't base our decision on the credit score. Should we stop pulling the credit score? It doesn't make sense to get the score, if we're not using it.

My opinion - if you don't base your decision on the credit score, don't get the credit score. Then you don't have to worry about disclosing the score and key factors.

So, if we get a score on employment applicants, we have to list key factors just like we would on loans?

Yes. It's a hard argument to make if you use the credit report but say you don't use the credit score if the score is showing on the report. So if the credit score is showing on the report and you use the report to take adverse action, you should disclose the credit score and key factors affecting the credit score.