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#2165835 - 02/26/18 05:25 PM HMDA - Credit score 7777
Anonymous
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Can someone please give me an example of when to use 7777 - Credit score is not a number? And if that option is used for the co-applicant credit score, what would the corresponding version of the credit scoring model be?
Thanks

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#2165838 - 02/26/18 05:29 PM Re: HMDA - Credit score 7777 Anonymous
Adam Witmer Offline
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I haven't really ever seen this but believe it would be some sort of rare internal scoring system that produces an "accept" or "deny" or a "pass/fail" instead of an actual number. The October 2017 CFPB HMDA filing Instructions don't really help but only reference code 7777 a few times:

Descriptions: 7777. Credit score is not a number

c. Use Code 7777 if your institution relied on a credit score that is not a number.

1) If Credit Score of Applicant or Borrower equals 7777 indicating a credit score that is not a number, then Applicant or Borrower, Name and Version of Credit Scoring Model should equal 7 or 8.
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#2165840 - 02/26/18 05:31 PM Re: HMDA - Credit score 7777 Anonymous
David Dickinson Offline
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David Dickinson
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Central City, NE
I haven't seen it either but came to the same assumption Adam describes.
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#2165843 - 02/26/18 05:34 PM Re: HMDA - Credit score 7777 Anonymous
Anonymous
Unregistered

Thanks Adam, so if we have a credit report for a co-applicant that is returned NOT SCORED: INSUFFICIENT CREDIT with a Transunion Classic 04 Score, how should that get reported?

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#2165884 - 02/26/18 07:41 PM Re: HMDA - Credit score 7777 Anonymous
Adam Witmer Offline
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I believe you would use code 8888 when there is no score. The CFPB originally had said to use code 0, but the preamble to the September 2017 final rule and the FIG appear to say to use code 8888.

From the FIG:

a. Use Code 8888 if the requirement to report the credit score does not apply to the
covered loan or application that your institution is reporting.


The preamble to the 9/13/17 HMDA amendments states the following:
"Regarding the request for guidance on reporting when a credit score is requested but none is available, § 1003.4(a)(15) requires reporting the credit score or scores relied on in making the credit decision, so a financial institution would report that the requirement is not applicable if it did not rely on a credit score.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2165910 - 02/26/18 09:04 PM Re: HMDA - Credit score 7777 Anonymous
Anonymous
Unregistered

Thanks for your help!

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#2197979 - 11/09/18 07:57 PM Re: HMDA - Credit score 7777 Anonymous
Compliance NABW Offline
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I was wondering about situations as well where "No Score" or the like is returned. I agree that the 9/13/17 preamble seems to imply to use "Not Applicable," but as is often the case with the CFPB clarifications, they just refer to the previous issuance that still leaves doubt on what the correct method would be based on the scenario. It seems to be clear that 8888 is used when a credit score was not relied on in making the credit decision. There may be cases where the "No Score" response is the reason for the denial, or was at least a factor in the denial decision. In those cases, it would seem that 7777 would be an appropriate code to report. I guess they tried to clarify with the 2019 FIG:

c. Use Code 7777 if your institution relied on a credit score that is not a number (e.g., a credit score of “Meets Threshold”). Code 7777 should not be used if a credit scoring model that produces numeric credit scores returns a result stating that the credit score could not be determined.

However, I still think "credit score could not be determined" does not necessarily correspond with "No Score." Also, the fallback option to Code 8888 doesn't seem to match precisely, due to what was stated above.

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#2198027 - 11/12/18 04:04 PM Re: HMDA - Credit score 7777 Anonymous
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
I agree this is confusing, but I also agree with Adam that we are to report 8888 when there is no score. I rad the 2019 FIG to clarify this:
Code 7777 should not be used if . . . the credit score could not be determined.

You're right that "No score" does not perfectly line up with this. It would be nice if the CFPB would simply state "When there is no score, report ______".
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