Please tell me if I have this totally out of whack!!

The Credit Score disclosure is not required when you have a consumer purpose loan secured by a Mobile Home only, no dirt.

The Notice to Home Loan Applicant would be required because we are taking the MH the consumer lives in as collateral on the loan.

I don't know what "Credit Score disclosure" you are referring to. There is nothing with that name referenced in the regulations.

As far as the NHLA, no dirt - no disclosure:

(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

I think the poster is referring to the RBP Credit Score Exception Notice, is that right?

If that is the case, the RBP rules cover any time a consumer credit report is used to make an underwriting decision for consumer credit (open- and closed-end) extended primarily for personal, family, and household purposes. It does not specify by type of collateral.

As for the NTHLA notice, see rlcarey's response above.

FACTA requires the "Disclosure to a Home Loan Applicant" but it does not require that "Dirt or Real Estate" be involved. If you pull a credit report with a credit score, you must provide the Credit Score Disclosure.

"Disclosure to a Home Loan Applicant"
Credit Score Disclosure

OK - I'm sorry for this rant and I don't mind having discussions regarding issues and I am the first to admit when I am wrong,

BUT PLEASE

don't use terms for disclosures that are not defined in the law or regulations. There is no reference to the two just quoted above. What are you referring too?????

Credit Score Disclosure may be a term that you use internally, but it means diddly to the rest of us. Please be specific so we can all stay on the same page.

FACTA requires the "Disclosure to a Home Loan Applicant" but it does not require that "Dirt or Real Estate" be involved.

What are you referring too? I quoted the law regarding when the NHLA has to be delivered.

If a dwelling secured application includes a co-signer, would the co-signer also get a NHLA disclosure since we are running a credit report on them also? It is a credit score on a consumer in connection with an application for a 1-4.

The law says "in connection with an application", it doesn't say the consumer has to be the applicant.


(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:

Is there any guidance on how 'reasonably practicable' is defined?