We opted to give the exception notice - consumer Credit Score Disclosure and use the model that includes the Notice to Home Loan Applicant for a real estate application - model H-3.

The rules at 1022.74(b) state a person is not required to provide a risk-based pricing notice to the consumer under §1022.72(a), (c), or (d) if the person provides an adverse action notice to the consumer under section 615(a) of the FCRA. I don't read it to say that this also applies to the exception to provide a consumer Credit Score Disclosure if the loan is denied and the adverse action notice is provided. However, the Consumer Compliance Outlook newsletter in 1Q12 says "Section 1022.72(a) of Regulation V (12 C.F.R. Part 1022 External Site) specifies when a creditor must provide a risk-based pricing notice to a consumer applying for credit, subject to the exceptions in §1022.74. If an application is denied and an adverse action notice is provided, a risk-based pricing or exception notice is not required. See §1022.74(b)"

The Notice to Home Loan Applicant rules at 609(g) doesn't have any exception for denials that I can see, but neither did it seem to me that there was an exception for the exception Credit Score Disclosure.

So if we have pulled a credit report -

1. Do we have to still provide the consumer Credit Score Disclosure for a denied loan application?
2. If not, must we provide a standalone Notice to Home Loan Applicant for a consumer real estate loan application even if denied?

Thanks in advance

You do not have to provide the notices required by 1022.72 & .74 but you do have to provide the notices required by 609.g. You can however use the exception notice as a substitute for the 609.g disclosure.