Do I assume correctly that if we order a credit bureau report and there is NO SCORE because of no credit history, the Notice to Home Loan Applicant and the Consumer Credit Score are not required to be disclosed?

I'd love to know the answer to this one. Are there a lot of people who apply for home loans who don't have a credit score?

"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 a 1-4 unites of residential real property shall provide the following to the consumer as soon as reasonably practicable."

Direct quote from the Act. I think the consensus is that if there is no score you could not have "used" the score so no disclosure would be necessary.

You have no idea how many credit reports that we pull on home loans like this in rural America. Not out of the question at all; in fact, one happened just this morning to prompt the question!

Does anyone have any other thoughts on this?

In my opinion, if a credit report is obtained- with or with out a score that falls in the ranges provided by the CRA -- you are identifying your institution as using a credit report and score to make a determination for a loan application. Therefore, a notice should be delivered if you would turn down an applicant based on lack of credit. I interpet the purpose of the notice to inform the cusomter of how the CRA is reporting thier information to increase consumer knowledge to allow them to dispute that data if incorrect.

Again this is my opinion, and I am looking for more information on this topic and a way to implement it.

I agree. The purpose of the Act is to inform the customer about what is on their credit bureau that contributed to your credit decision. That includes, in my mind, the fact that they don't have a credit score.

I agree as well. If your institution normally relies on reported scores in making the credit decision, then disclosure would be required even when the applicant has no score.

Isn't the score something that you contract for with the CRA? I seem to remember it as an option several years ago. Maybe some banks are not getting scores on their reports. No score, no disclosure.

You're right, SoccerMom, but the poster's question was what to do if the report that normally generates a score does not because the borrowers have no credit history. I've never seen one but I'm assuming the space after credit score is left blank or marked 0 and the factors state no available credit history.

Does anyone have any other thoughts on this?
Actually the situation im looking at is the applicant has no credit history, the CRA provided the report with a number in the score area, such as 99999 (the actual numbers seem to be different per CRA)so I dont believe it is an actual score because it does not fit in the CRA provided scoring range. I believe I was told,that a numeric value is put in that field to allow the completion of the report. So basically the question is
do we:
1- not give a notice to the applicant because an actual score was not generated

or

2- still provide the notice because
-we are an entity that uses credit scores to make loan decisions and are required to report the information provided by the CRA
-to notify the applicant that a report was obtained and this is the information the CRA provided so the customer may dispute the "score" if not accruate

I was hoping anyone had already run into this....
my thought was to still send one, because in my opinion the purpose of this disclosure was to allow the applicant knowledge of the application and the data provided to the lender by the CRA (read the notice language)

Does anyone have any other thoughts on this?
To answer SoccerMom, we normally do get scores, except when the customer has absolutely no credit to base a score on.

No score - no disclosure

In order to eliminate "exceptions" in the procedures, I'm advocating that we would generate the disclosure and notice and simply note, "No Credit Score". bjp and Rob K are right on.

Makes training and compliance simpler for the troops.