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#2264847 - 01/18/22 09:43 PM HMDA Credit Scores
Anonymous
Unregistered

If I have two applicants, pull a tri-merge, use the middle score from each, and then use the lower of the two middle scores what is the accurate way to report this on HMDA. We currently report both middle scores and repositories for each on HMDA lar. Should we be reporting only the low score and repository and then N/A for those two fields for the other applicant?

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#2264858 - 01/19/22 02:51 PM Re: HMDA Credit Scores Anonymous
Island Dreaming Offline
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Joined: May 2009
Posts: 219
midwest
Anon - the Reg C official interpretation to Paragraph 4(a)15 discusses multiple applicants and multiple credit scores in depth and would be the source for you to use to determine how it relates to your institutions processes.
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#2264938 - 01/20/22 06:03 PM Re: HMDA Credit Scores Island Dreaming
Anonymous
Unregistered

Thanks for responding. I've looked at that section but it seems not everyone interprets it the same - as is the case many times in compliance!

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#2264955 - 01/20/22 09:48 PM Re: HMDA Credit Scores Anonymous
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,013
Bloomington, IN
What is the score used in making the credit decision? That would be the score to report.

2. Credit score—multiple credit scores. When a financial institution obtains or creates two or more credit scores for a single applicant or borrower but relies on only one score in making the credit decision (for example, by relying on the lowest, highest, most recent, or average of all of the scores), the financial institution complies with § 1003.4(a)(15) by reporting that credit score and information about the scoring model used.

Borrower 1 middle score 732 Borrower 2 middle score 688

688 is the lower of the 2 middle scores and if I'm reading your post correctly 688 would be score relied on for making the credit descision.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2271916 - 06/21/22 08:21 PM Re: HMDA Credit Scores Dan Persfull
kmenard Offline
Member
Joined: Oct 2014
Posts: 66
Would it be ok to report the 688 in the applicant field and 8888 in the co-applicant field?

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#2271928 - 06/21/22 09:22 PM Re: HMDA Credit Scores kmenard
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,938
Idaho
Originally Posted by kmenard
Would it be ok to report the 688 in the applicant field and 8888 in the co-applicant field?

This is how we do it, regardless of which applicant has the lowest mid score.
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