Sarah,
One quick correction, the notice on the Adverse Action Notice is not the Credit Score Disclosure, but instead it is the Risk Based Pricing Notice. I’m going to assume that as a bank you’ve decided to go with the Exception Notice (Credit Score Disclosure), as most banks have chosen to go with.
With that assumption, you would need to give the applicant the Credit Score Disclosure for no credit score, just as you normally would do. That would be Model form H5. As far as your Adverse Action Notice, you would leave the Risk Based Pricing Notice section off.
If hope this helps.