Credit score on report - not used in decision

Posted By: AuditorK

Credit score on report - not used in decision - 01/17/13 01:46 PM

I'm looking for a list of all the compliance violations we will be subject to by pulling credit reports that include credit scores, but not actually using the score in the credit decision.

We do not provide any disclosures related to credit scores at this time.

Thanks for your time and expertise!
Posted By: rlcarey

Re: Credit score on report - not used in decision - 01/17/13 01:50 PM

If you don't use it, why pull it. Drop them and save yourself some money. Making an argument that it never influences a loan officer is a very hard argument to make stick.

If you are not risk based pricing based on the credit report information (i.e., rates only set based on collateral type, etc.) then you can make an argument that you are exempt from the risk based pricing notice.

However, not making the FCRA AAN credit score disclosures is going to tougher.
Posted By: Dan Persfull

Re: Credit score on report - not used in decision - 01/17/13 02:45 PM

We do not provide any disclosures related to credit scores at this time.

However, not making the FCRA AAN credit score disclosures is going to tougher.

And the FCRA 609(g) credit score requirements for loans secured by 1-4 real property.
Posted By: swiggles

Re: Credit score on report - not used in decision - 01/17/13 03:27 PM

Don't credit reports typically come with the notice attached? Just fold the notice, put it in an envelope and mail it to the applicant.....simple.
Posted By: rlcarey

Re: Credit score on report - not used in decision - 01/17/13 04:26 PM

Don't credit reports typically come with the notice attached?

If you pay for the service.
Posted By: Starter

Re: Credit score on report - not used in decision - 02/08/13 03:55 PM

I am still a little confused. What if a Bank pulls a credit report and uses the information in the credit report to make a decision on the loan, but they do not use the "score" in their decision. In this case, would it be ok if they did not include the additional credit score notice requirement on the adverse action form?
Posted By: swiggles

Re: Credit score on report - not used in decision - 02/08/13 04:26 PM

My opinion, if you have the score, and you don't use the RB notice method, you provide the RB Exception Notice when you obtain the report and you include pretty much the same information on the Reg B/FCRA Adverse Action Notice. As Randy said, if you don't use the credit score, don't have it included in the reports you obtain.
Posted By: Starter

Re: Credit score on report - not used in decision - 02/08/13 05:29 PM

thanks all - this totally helped