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#2226544 - 12/02/19 05:33 PM AAN and disclosure of credit score
TeamComply Offline
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Joined: Aug 2016
Posts: 393
We are setting up our AANs with a new provider. What is technically correct to disclose in the credit score field, when the applicant has no credit score? For example:

Your credit score: _____ Date: ____ Score range from a low of ___ to a high of ___.

Would we disclose "0" or "N/A" on the "Your credit score: ___" field or is it bank preference?
Looking for the regulation or guidance that addresses this. Thanks!

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#2227236 - 12/11/19 09:49 PM Re: AAN and disclosure of credit score TeamComply
Cloud9 Offline
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Joined: Jul 2008
Posts: 200
I'm tagging on to this question as I would like to know also. Thanks.

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#2227250 - 12/11/19 10:50 PM Re: AAN and disclosure of credit score TeamComply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
You leave the disclosure off of the form.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2237364 - 05/29/20 05:47 PM Re: AAN and disclosure of credit score TeamComply
Nicole Offline
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Joined: Nov 2018
Posts: 117
We have an FDIC examiner asking why we didn't disclose this information our response was there is no credit score information to disclose and they are indicating that it should have been like above due to FCRA Disclosure rules? How do i argue this is not correct?

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#2237365 - 05/29/20 06:02 PM Re: AAN and disclosure of credit score TeamComply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
You are required to disclose the numerical credit score used by the lender in the decision under 615(a)(2)(A) - if there is no score, then a numerical score was not used, which then makes the disclosure moot. Ask them for their citation to support there side of the argument. No score is not zero. There is no number associated with a no score.


Sec. 615. Requirements on users of consumer reports

(a) Duties of users taking adverse actions on the basis of information contained in consumer reports. If any person takes any adverse action with respect to any consumer that is based in whole or in part on any information contained in a consumer report, the person shall

(1) provide oral, written, or electronic notice of the adverse action to the consumer;

(2) provide to the consumer written or electronic disclosure

(A) of a numerical credit score as defined in section 609(f)(2)(A) used by such per- son in taking any adverse action based in whole or in part on any information in a consumer report; and

(B) of the information set forth in subparagraphs (B) through (E) of section 609(f)(1);
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2237381 - 05/29/20 08:36 PM Re: AAN and disclosure of credit score TeamComply
Nicole Offline
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Joined: Nov 2018
Posts: 117
Thank you so much!

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