3 scores on NHLA?

Can we still disclose 3 credit scores on the Notice to Home Loan Applicant if we pull a tri-merge credit report? Our loan document vendor is saying that the Reg. changed and you can only disclose one score as of 1/1/11.

I don't see anything in FCRA 609(g)(1)(D) that says you have to use only ONE score.

Hey Funky,

Did you figure this out? I would be interested to.

The 609(g) rule did not change but under the RBP rules you are allowed to substitute the H-3 exception notice for the NHLA requirements. On the RBP exception notices you only disclose one score.

Talking about tri-merge....under ECO published 7/15/11, pg 41597 says "expects that creditors will have policies and procedures to determine which of the multiple credit scores was used in taking adverse action." I would assume examiners will be looking for this.