With regards to section 609(g) - (g) Disclosure of Credit Scores by Certain Mortgage Lenders

(1) In general. Any person who makes or arranges loans and who uses a consumer credit score, as defined in subsection (f), in connection with an application initiated or sought by a consumer for a closed end loan or the establishment of an open end loan for a consumer purpose that is secured by 1 to 4 units of residential real property (hereafter in this subsection referred to as the “lender”) shall provide the following to the consumer as soon as reasonably practicable

How is everyone treating Interim/Temporary Construction Loans for 1 to 4 family dwellings. Are you providing the "NHLA" disclosure on the type of loan or not? Your assistance is much appreciated.

There is no temporary loan exemption in 609(g). We provide the notice.

Thank you Dan. I appreciate your assistance.

In reading section 609(g) I'm confused as to whether the Notice to Home Loan Applicant is required if no credit score is provided. We have a circumstance where a recently relocated canadian citizen applied for credit and they did not have a credit score, so no NHLA was provided. Our CRA vendor states it will not be supplied in that case. I can not find where in the regulation is states it's not required.

Any person who makes or arranges loans and who uses a consumer credit score

If they don't have a score, how can you use it?