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Score in Chex System for Adverse Action Deposit

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Do you provide a score, contained in a Chex Systems report, in an adverse action notice for deposit accounts? I'm working on our deposit audit and am confused by the definition of a credit score. Section 615 of FCRA refers you to 609 (f)(2)(A) for this definition: (A) CREDIT SCORE.--The term "credit score"-- (i) means a numerical value or a categorization derived from a statistical tool or modeling system used by a person who makes or arranges a loan to predict the likelihood of certain credit behaviors, including default (and the numerical value or the categorization derived from such analysis may also be referred to as a "risk predictor" or "risk score"); and (ii) does not include-- (I) any mortgage score or rating of an automated underwriting system that considers one or more factors in addition to credit information, including the loan to value ratio, the amount of down payment, or the financial assets of a consumer; or (II) any other elements of the underwriting process or underwriting decision. ​COMPLIANCE FCRA, Credit Score, Credit report​

If you are talking about a Qualifile score, the answer is yes, the numerical score disclosure must be included.

First published on 04/22/2018

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