Current bank customer that has multiple commercial term & revolving lines of credit with us. One of their commercial lines of credit was recently renewed and with that process new credit reports were pulled along with scores. At the same time as the renewal of their commercial line of credit the customer applied for a consumer real estate purchase loan (TRID). The loan officer did not send the Notice to Home Loan Applicant because they said that they used the same scores/reports that were pulled for the application of the renewal of the commercial line of credit.

Should they have sent the Notice to Home Loan Applicant in this case? Thanks.

Ignoring the contract issues potentially surrounding the use of a credit report for multiple purposes, it certainly sounds like they used the credit score for a consumer mortgage. The requirement is triggered by the use (not the pull), so yes it should have been sent.

Any person who makes or arranges loans and who uses
a consumer credit score, as defined in subsection (f), in connection
with an application initiated or sought by a consumer for a closed end
loan or the establishment of an open end loan for a consumer purpose
that is secured by 1 to 4 units of residential real property (hereafter in
this subsection referred to as the “lender”) shall provide the following
to the consumer as soon as reasonably practicable

Thank you - makes sense to me!