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#2186843 - 07/25/18 08:58 PM Credit Score Disclosure and Notice to Home Loan Ap
Cloud9 Offline
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Joined: Jul 2008
Posts: 208
Am I correct that on both withdrawn and denied home loan applications, we still must provide the Credit Score Disclosure and Notice to Home Loan Applicant? I don't see any exclusions, even if the withdrawn or denial takes place within a certain number of days, e.g. 3. Thank you!

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#2186850 - 07/25/18 09:57 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Cloud9
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Correct, if you are using the exception notice under 1022.74.
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#2186896 - 07/26/18 01:08 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Cloud9
Cloud9 Offline
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No, we don't do risk based pricing. I was just referring to the Consumer Credit Score Disclosure which also has the Notice to Home Loan Applicants attached. I'm sorry, I probably am not using the correct terminology.

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#2186899 - 07/26/18 01:13 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Cloud9
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Consumer Credit Score Disclosure

Describe please as I am not sure what you are referring to?

Are you referring to a disclosure similar to Model H-3?

https://www.bankersonline.com/regulations/12-1022-apph#H3
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2186915 - 07/26/18 02:17 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Cloud9
Cloud9 Offline
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Posts: 208
I'm referring to the notice required by 15 USC 1681g(g) Disclosure of Credit Scores by Certain Mortgage Lenders. Sorry for the confusion.

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#2187034 - 07/26/18 08:14 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Cloud9
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
The disclosure requirements of 609(g) does not have any exemptions for not providing the credit score and NHLA disclosures. You can however substitute the Model H-3 disclosure for the 609(g) disclosures.
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#2189389 - 08/16/18 04:20 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Cloud9
iheartcompliance Offline
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Would you only be permitted to use Model form H-3 if you in fact RBP?

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#2189519 - 08/17/18 12:35 PM Re: Credit Score Disclosure and Notice to Home Loan Ap iheartcompliance
Adam Witmer Offline
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Joined: Sep 2010
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Originally Posted By iheartcompliance
Would you only be permitted to use Model form H-3 if you in fact RBP?

No. You can use the H-3 disclosure in place of the 609(g) disclosures even if you don't RBP.

From the preamble to the 2010 final rule:

“Appropriate use of model form H-3 or model form B-3 is also intended to be compliant with the disclosure that may be required under section 609(g) of the FCRA.”
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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.
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#2189590 - 08/17/18 04:29 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Cloud9
iheartcompliance Offline
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Posts: 239
To clarify, are the model form H-3 and the NTHLA disclosures only sent out on consumer purpose, dwelling secured loans?

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#2189592 - 08/17/18 04:36 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Cloud9
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
If you don't RBP, yes. That is because the 609(g) requirement is driving the need for these disclosures and that section only applies to dwelling secured consumer loans.
_________________________
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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#2203305 - 01/17/19 06:29 PM Re: Credit Score Disclosure and Notice to Home Loan Ap Dan Persfull
kbaird Offline
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Joined: Dec 2015
Posts: 35
I want to piggy back on this to try to clear some confusion on my part.

If the credit report comes back with no score or a 0, I understand the Credit Score Disclosure is still issued to the applicant and the credit score portion is either left blank or maybe a 0 inserted. However, in that scenario, is the Notice to Home Loan Applicant still required?

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