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#503861 - 02/23/06 07:24 PM Credit Score Disclosure
In Need of Help 101 Offline
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Joined: Jan 2006
Posts: 574
If you have a husband and wife applying for a loan that is for a consumer purpose and is secured by a 1-4 residential property, can we give one credit score disclosure that includes both the husband and wife credit score information, or do you give one disclosure to each applicant?

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Lending Compliance
#503862 - 02/23/06 08:56 PM Re: Credit Score Disclosure
Anonymous
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According to Jack Holzknecht in his "How to Audit for Compliance with the FACT Act" seminar, "The FCRA requires a financial institution to disclose all of the credit scores that were used in these transactions. For example, if two joint applicants apply for a mortgage loan to purchase a single-family-residence and the lender uses both credit scores, then both need to be disclosed. The statue specifically does not require more than one disclosure per loan; therefore, if multiple scores are used, all of them can be inclusded in one disclosure containing the Notice to the Home Loan Applicant.

I hope this helps.

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#503863 - 02/23/06 08:56 PM Re: Credit Score Disclosure
sue's mom Offline
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sue's mom
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IL
We prepare a disclosure for each applicant. They all go in the same packet to the customer.

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#503864 - 02/23/06 09:42 PM Re: Credit Score Disclosure
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
We also give a separate disclosure to each applicant.
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#503865 - 02/24/06 03:26 AM Re: Credit Score Disclosure
Truffle Royale Offline

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This has been discussed a couple of times before. A search would give you the chance to read a bunch of others' input on this subject.

fwiw, we print the disclosure that is generated by our tri-merge cbr and send that to our borrowers.

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#503866 - 02/24/06 03:33 AM Re: Credit Score Disclosure
Dan Persfull Offline
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Dan Persfull
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Posts: 47,017
Bloomington, IN
Quote:

This has been discussed a couple of times before. A search would give you the chance to read a bunch of others' input on this subject.

fwiw, we print the disclosure that is generated by our tri-merge cbr and send that to our borrowers.




Ditto, and ours is only one notice with all credit scores disclosed.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#503867 - 07/11/06 03:35 AM Re: Credit Score Disclosure
Jan94 Offline
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Joined: Mar 2001
Posts: 828
USA
I was going back through our procedures and thought our banks did this the same way, but found that they do not. The banks are credit scoring and for joint applicants, they use the best credit score in the decisioning process. That is the applicant who gets the notice. In the example above it states that "the lender uses both credit scores" and in our situation they do not, they just use the best score. I'm a little concerned as it would appear that the banks are still using both scores to make a determination of which is the "best" and a notice probably needs to be provided to both applicants. Would appreciate some other thoughts? Haven't had a regulator state that we were doing this wrong (yet) . Thanks.

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#503868 - 07/11/06 12:44 PM Re: Credit Score Disclosure
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,017
Bloomington, IN
If you pull 3 credit scores and your policy is to use the middle score. How do you determine what is the middle score if you do not use all three scores?

I agree with you, the scores are being used and should be disclosed.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#503869 - 07/11/06 08:09 PM Re: Credit Score Disclosure
JohnDoe Offline
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Joined: May 2005
Posts: 140
Another point in agreement with Dan is permissable use.
If you didnt use the score why did you pull it?
Hope that helps as well.

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