Thanks Ted,
I read the referred sections and now I am more confused. 222.74(d)(3) (form H-3) refers you to FCRA 609(g). 609(g) refers you to 609(a)which does not address timing as I read it.
222.74(e)(3) (form H-4) says "as soon as reasonably practicable after the credit score has been obtained, but in any case at or before consummation in the case of closed-end credit or before the first transaction is made under an open-end credit plan." Two questions: does consummation mean loan closing or something else, and why is Form H-4 referring to closed-end credits ( I thought H-4 was specific to open-end credits only, with H-3 for closed-end credits).
222.74(f)(4) says "as soon as reasonably practicable after the person has requested the credit score, but in any event not later than consummation of a transaction in the case of closed-end credit or when the first transaction is made under an open-end credit plan." Does this mean that Form H-5 need not be given unless the customer requests it? Additionally, what is a "transaction" as used in this section?
It seems that there is a different standard
for each form H-3, H-4, and H-5.
I know this is a lot but can you provide any clarification.