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#2256280 - 07/02/21 06:41 PM Qualifile scores and ranges on Deposit AAN's
dutchbltz Offline
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Joined: Oct 2015
Posts: 207
Qualifile/Chexsystems either isn't understanding my question or else is being intentionally unhelpful.

We utilize Qualifile in our determination of opening a deposit account. Therefore, we are going to begin providing the Qualifile score and range of scores on the adverse action notices we provide, as required under FCRA. Our core system told us that the 'range' is not something they can pull in, and so I contacted Qualifile to obtain the range. They told me that the range is 100-899, with 100 being the worst. All good so far, right?

HOWEVER.

When we get a 'decline' from Qualifile, the score reported is almost always 9992. I have only been able to find 1 circumstance that this was not the case. Qualifile is insistent (through many emails) that the range is 100-899, and quite frankly I do not understand how this can be with all the 'decline' 9992 scores we have. I am bothered to disclose to potential clients that scores range from 100-899 but yet their score was 9992.

I'm clearly missing something here. Has anyone else ran into this? If so how have you handled it?

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#2256283 - 07/02/21 06:52 PM Re: Qualifile scores and ranges on Deposit AAN's dutchbltz
InFairness, CRCM Offline
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InFairness, CRCM
Joined: Nov 2010
Posts: 919
USA
Not a Qualifile user, but you might try asking what score, if any, will be returned if an applicant is unscorable.
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#2256284 - 07/02/21 06:58 PM Re: Qualifile scores and ranges on Deposit AAN's InFairness, CRCM
dutchbltz Offline
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Joined: Oct 2015
Posts: 207
If 9992 is their 'unscorable' score, would you still disclose the range? I feel like this is so confusing to a consumer. I'm confused about it myself.

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#2256288 - 07/02/21 07:36 PM Re: Qualifile scores and ranges on Deposit AAN's dutchbltz
Andy_Z Offline
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Andy_Z
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On the Net
Just like the bank, the vendor is going to have to support their conclusion. My guess is 9992 is not a score, but a code that means no file or something similar as scores are 3 digits. It is something you each need to understand to better serve customers.
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#2256290 - 07/02/21 08:16 PM Re: Qualifile scores and ranges on Deposit AAN's dutchbltz
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
If 9992 means that the applicant does not have a credit score, then you owe them an adverse action notice - you just don't have a score or range of scores to disclose. You can just tell them why under 615(a)(1) and then 615(a)(2) does not apply..

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;
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#2256304 - 07/06/21 02:01 PM Re: Qualifile scores and ranges on Deposit AAN's dutchbltz
dutchbltz Offline
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Joined: Oct 2015
Posts: 207
Per Qualifile:

"9992 - A decision is based on a policy rule prior to calculating a QF Score (there's a fraud closure from within the last 5 years at any FI or an account abuse closure from their own FI within the last 5 years). Results in decline response"

Every one of these people who gets a 9992 (which is pretty much every 'decline' qualifile we've ever received - could only find 1 decline ever where that was not the score) has a closure at a prior bank that is unpaid. Without a doubt, the reason we don't open the account is because of the information received from the consumer reporting agency. (without the qualifile report, indeed we WOULD have opened it!)

So... provide a notice covering 615(a)1, 3, and 4, but completely skip 2?

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#2256306 - 07/06/21 02:24 PM Re: Qualifile scores and ranges on Deposit AAN's dutchbltz
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
If there is no score, then you should be using the standard ChexSystems AAN - which they used to provide forms to their clients. Like this one or similar: https://secure.andera.com/PDFS/AdverseActionChexSystems.pdf
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#2256309 - 07/06/21 03:38 PM Re: Qualifile scores and ranges on Deposit AAN's dutchbltz
dutchbltz Offline
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Joined: Oct 2015
Posts: 207
Ok, thanks. This was helpful.

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