I have a question about the credit score that was used in the credit decision and an application with multiple borrowers. If we have an application with 4 borrowers being reported on the HMDA LAR and we use a single credit score method for credit. Is it implied that the DI and credit score we report on the HMDA LAR for the applicant and co-applicant would match? Meaning that the DI and credit score we report for the applicant is for the same person and the DI and credit score for the co-applicant is for the same person. I understand that this may seem like an elementary question but unfortunately this is where I'm at in my compliance day, send help.

The question being posed to me is if we can report the third borrowers credit score which was used in the credit decision (say 750) in the co-applicants credit score position on the LAR. The LAR would then have the actual co-applicants DI with the third borrowers credit score.

They don't have to match. We put the credit score we use in applicant slot and NA for co-app regardless of whose score we used.

1003.4(a)(15)- Comment3 Credit score - multiple applicants or borrowers. In a transaction involving two or more applicants or borrowers for whom the financial institution obtains or creates a single credit score and relies on that credit score in making the credit decision for the transaction, the institution complies with § 1003.4(a)(15) by reporting that credit score for the applicant and reporting that the requirement is not applicable for the first co-applicant or, at the financial institution's discretion, by reporting that credit score for the first co-applicant and reporting that the requirement is not applicable for the applicant.

This makes complete sense. When we use the applicants score we report the score under the applicant, when we use the co-applicant score we report it under the co-applicant, and the other is reported as NA. In situation based on that

the institution complies with § 1003.4(a)(15) by reporting that credit score for the applicant and reporting that the requirement is [i]not applicable for the first co-applicant [/i]or, at the financial institution's discretion, by reporting that credit score for the first co-applicant and reporting that the requirement is not applicable for the applicant

It seems like NA and NA fits this situation.

You need to report the score you used. It doesn't matter where you put it. It says OR not AND. You can't use a score and report not applicable.