We pull tri-merge credit reports for our mortgages. On our AANs, which agencies go into the "We also obtained your credit score from the consumer reporting agency..." section? Is it all three scores? Or just the median one (which is the one we use to underwrite).

Thanks!

We list all three, even though we use the low middle to underwrite.

That was what I was thinking, too. Seems like if you pull all three, you need to tell them all three. Thanks!

9. Combined ECOA–FCRA disclosures. The ECOA requires disclosure of the principal reasons for denying or taking other adverse action on an application for an extension of credit. The Fair Credit Reporting Act (FCRA) requires a creditor to disclose when it has based its decision in whole or in part on information from a source other than the applicant or its own files. Disclosing that a credit report was obtained and used in the denial of the application, as the FCRA requires, does not satisfy the ECOA requirement to disclose specific reasons. For example, if the applicant's credit history reveals delinquent credit obligations and the application is denied for that reason, to satisfy §1002.9(b)(2) the creditor must disclose that the application was denied because of the applicant's delinquent credit obligations. The FCRA also requires a creditor to disclose, as applicable, a credit score it used in taking adverse action along with related information, including up to four key factors that adversely affected the consumer's credit score (or up to five factors if the number of inquiries made with respect to that consumer report is a key factor). Disclosing the key factors that adversely affected the consumer's credit score does not satisfy the ECOA requirement to disclose specific reasons for denying or taking other adverse action on an application or extension of credit. Sample forms C–1 through C–5 of Appendix C of the regulation provide for both the ECOA and FCRA disclosures. See also comment 9(b)(2)–1.


If you used all 3 scores in the adverse action disclose all 3, if you only used one of the 3 disclose the one used.

Does using the median score constitute "using" all three scores since we had to look at all three to determine which one the middle was?

High Score 785
Middle Score 760
Low Score 750

High and Low scores are discarded and the middle score is used in the decision. The middle score is disclosed.

Do all of your scores have a common range?

The most common are:
Transunion is 300-850
Equifax is 300-850
Experian is 360-840

Even though the differences are slight, they are not all the same

Dan - thank you! That makes sense.

Rocky - ours are actually kind of odd.
Transunion is 309-839
Equifax is 334-818
Experian is 320-844.

Those are correct on our AANs.