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#2194129 - 09/28/18 03:43 PM Adverse Action - No Score on the Credit Report
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
I would like to see if opinions on this topic have changed.

What do you (anyone who wants to answer) indicate on an Adverse Action Notice when the applicant has a report, but not enough tradelines to generate a score?

I have been indicating "N/A" for the score and then, in the factor section, I type the verbiage from the credit report, such as "not enough information to calculate a score."

One of my software systems allows this, the other one does not.

And....for the software that DOES allow it, there is a checkbox which states "Score not Available." You would think that checking that box would cause some sort of disclosure to appear on the AAN automatically. It causes nothing.

What say you?.....anyone?
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#2194131 - 09/28/18 03:48 PM Re: Adverse Action - No Score on the Credit Report swiggles
raitchjay Offline
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Posts: 8,701
OK
I leave that section blank. You cannot provide a score, or the reasons for a score, when there is no score.
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#2194140 - 09/28/18 04:43 PM Re: Adverse Action - No Score on the Credit Report swiggles
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,614
From the preamble to the 2011 final rule:

"Disclosure that no credit score is available. In some cases, a creditor may try to obtain a credit score for an applicant, but the applicant may have insufficient credit history for the consumer reporting agency to generate a credit score. One commenter asked that the creditor have the option to provide the applicant notice that no credit score was available from a consumer reporting agency in the space available for the credit information disclosure.

Section 1100F only applies when a creditor uses a credit score in taking adverse action. The creditor cannot disclose credit score information if an applicant has no credit score. Nothing in section 1100F of the Dodd-Frank Act prevents a creditor, however, from providing the applicant notice that no credit score was available from a consumer reporting agency, although section 1100F does not require such notice."
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2194199 - 09/28/18 07:57 PM Re: Adverse Action - No Score on the Credit Report swiggles
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
Thanks. Since we base our decision on the fact that the applicant has no score, I suppose Reg B would cover that because a reason for denial would likely be "limited credit experience." I have seen reports with 2 or 3 pages of paid as agreed "stuff" but none of it qualifies for calculating a score, evidently. I'm thinking pay day lenders or some sort of finance company, who may report accounts paid as agreed, but the accounts are not the type that the CRA considers in creating a score.
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