We have an application that we denied based on collection actions or judgements, which were discovered when pulling the credit report. The catch is that the applicant does not have a credit score. It simply says, Not Scored: Insuffiecient Credit. We were wondering if we should still include the Credit Score Disclosure on the Adverse Action Notice since the reasons we denied the application were based off of information on the credit report. If we are to include the disclosure, how should we proceed to fill it out?
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.