Compliance Alliance Q&A 9/18/18
If it is in our loan policy not to use the credit score to base our credit decision on, but we do pull the real estate credit report for the disclosures, we don’t need to report the credit score on the HMDA LAR since we do not rely on the score to make a decision, correct?
Yes, that's correct - if the credit score wasn't relied on in making the credit decision, you're not required to report it for HMDA purposes, even if the credit report was pulled.
TRANSACTIONS FOR WHICH NO CREDIT SCORE WAS RELIED ON.
If a financial institution makes a credit decision without relying on a credit score for the applicant or borrower, the financial institution complies with § 1003.4(a)(15) by reporting that the requirement is not applicable.
Comment 5 to 1003.4(a)(15): https://www.consumerfinance.gov/eregulations/1003-Subpart-Interp/2017-18284_20180101#1003-4-a-15-Interp-5
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