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Credit Bureau Report - No Credit Score Given

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Our bank routinely pulls credit bureau reports for all new loan requests. Although credit scores are only one of the criteria used to make a decision on a loan request, a poor score would weigh heavily on a credit decision. With regard to the FACTA provision of providing Credit Score Disclosures to residential mortgage loan applicants, a question arises about those applicants whose credit bureau we request and the report is returned without a credit score. The lack of a score is sometimes a factor in determining the decisioning of an application, the need for a co-signer, or even the interest rate that may be charged. Should a customer with a credit bureau history, but no score, be supplied with the notice?

FCRA (609(g)) requires the credit score notices when a creditor "makes or arranges loans and who uses a consumer credit score." If the credit report does not contain a credit score, the notices are not triggered.

First published on 9/07/09

First published on 09/07/2009

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