Timing of Credit Score Disclosure

From an operational standpoint, it's "reasonably practicable" to provide the Credit Score/Home Applicant disclosure at closing or with the adverse action notice. Could this be an issue because it may be several days after the credit report was obtained?

A credit report is the first thing we do. Why not send it out with the Good Faith Estimate and other disclosures?

We are sending ours out with the early disclosures.

Ditto.

We are sending out the Credit Score disclosure listing the actual credit score within 5 days of pulling the credit report. I believe that the FACT Act states it must be within a "reasonable time" and to me waiting until closing is not a reasonable time. I know that we will get lots of calls either asking what this notice is or asking if this means their application has been approved. I'm in the middle of training all appropraite staff on all FACT Act effective as of 12/1/04, this being part of the training.

The FACT Act actually states that the disclosure is to be given "as soon as reasonably possibly."

My copy says "as soon as reasonably practicable." The word "possibly" there doesn't make any sense.

Does this notice have to be signed by the consumer? I couldn't find anything that said a signature is a requirement.

Here is a response to this very question I received from FDIC

"No, no signature or burden of proof. We'll be examining this by looking
at policies, practices, etc., just like any other disclosure. It's up
to each bank to decide how best to set up their program."

-Chris