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An FI pulls a credit report (consumer transaction) but does not ask for nor does a credit score appear on the credit report. In order words, they use credit report information but no credit score. What disclosures are required for a) a transaction secured by a dwelling and b) a transaction not secured by a dwelling. Which model credit score disclosure? If dwelling secured, is the Notice to Home Loan Applicant required if no credit score was used? Can you also point to regulatory standards.
I assume you do not use the Risk Based Pricing notices and are asking about the exception notices (see 12 CFR 1022.72-74). If a credit score is not included you would use model form H-5 for transactions both secured by, and not secured by, a dwelling. Section 609(g) of the FCRA only requires the Notice to the Home Loan Applicant if a credit score is used
609(g)(1)(D): Any person who makes or arranges loans and who uses a consumer credit score, as defined in subsection (f), in connection with an application initiated or sought by a consumer for a closed end loan or the establishment of an open end loan for a consumer purpose that is secured by 1 to 4 units of residential real property (hereafter in this subsection referred to as the “lender”) shall provide the following to the consumer as soon as reasonably practicable: …
(D) Notice to home loan applicants. A copy of the following notice, which shall include the name, address, and telephone number of each consumer reporting agency providing a credit score that was used…
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