If credit is ran on the applicants, and the application is denied or withdrawn, but was not due too the credit, woud we still report the credit scores, and credit provider? The credit wasn't the reason for the denial or w/d....

Thank you.

From the FIG: A Financial Institution relied on a credit score in making the credit decision if the credit score was a factor in the credit decision, even if it was not a dispositive factor.

You do not report a credit score if the file is closed for incompleteness or withdrawn before a credit decision is made however.

I'm sorry, I'm not understanding your reply burke116.

So if we have ran the credit on the applicants, but the credit was not the reason for denial....then we wouldn't report the credit when reporting our HMDA, even though we did pull their credit??

You enter the score(s) relied on in making the credit decision. It further explains that you still relied on a score even if it was not a dispositive factor in the credit decision. If the file is withdrawn before a decision is made or closed for incompleteness, you did not make a credit decision, so you did not rely on a credit score. Hope that helps

You have two different questions here.

If the application was denied, you report the score. If the application was withdrawn, you list NA.

From the commentary to Regulation C:
"Paragraph 4(a)(15)
1. Credit score—relied on. Except for purchased covered loans, § 1003.4(a)(15) requires a financial institution to report the credit score or scores relied on in making the credit decision and information about the scoring model used to generate each score. A financial institution relies on a credit score in making the credit decision if the credit score was a factor in the credit decision even if it was not a dispositive factor. For example, if a credit score is one of multiple factors in a financial institution's credit decision, the financial institution has relied on the credit score even if the financial institution denies the application because one or more underwriting requirements other than the credit score are not satisfied."

Also from the commentary:
"4. Transactions for which no credit decision was made. If a file was closed for incompleteness or the application was withdrawn before a credit decision was made, the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. For example, if a file is closed for incompleteness and is so reported in accordance with § 1003.4(a)(8), the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant. Similarly, if an application was withdrawn by the applicant before a credit decision was made and is so reported in accordance with § 1003.4(a)(8), the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable, even if the financial institution had obtained or created a credit score for the applicant or co-applicant."

Catm, the key word is "dispositive" which is a fancy way of saying it was or wasn't the deciding factor. So if you normally consider credit scores in your underwriting practices, and you deny some borrowers if their score is too low, and you pulled credit on this customer and you made a credit decision to deny the loan for a factor other than credit, then you probably still relied on the credit score in reaching your decision, it just wasn't the deciding factor in that decision. If nothing else, you probably at least determined that it was not a high enough score to compensate for whatever other weaknesses led you to deny the loan. In that case, you would still report the score. However, if the application was withdrawn before you made a credit decision, then you would not report the score.

Thank you all so much!

I tend to resist doing things I don't think I need to. But some cases say, if you have it,and it was in ANY way used, it's easier to report it than PROVE that it wasn't a factor.