I just had a banker ask me if we need to send the credit score disclosure (including reasons that affect the score, etc.) when a credit report is pulled as part of an annual review or if the account becomes deliquent. I cannot locate this question in the archives.

Thanks for any replies.

No = Disclosure of Credit Scores by Certain Mortgage Lenders

(1) In general. Any person who makes or arranges loans and who uses a consumer credit score, as defined in subsection (f), in connection with an application....

There is no application. However, if you take adverse action, an FCRA adverse action notice will be in order.

Thank you for the quick response. It makes sense to me.

609(g)(E):

(E) ACTIONS NOT REQUIRED UNDER THIS SUBSECTION.--This subsection shall not require any person to--

(iii) disclose any credit score or related information obtained by the user after a loan has closed;


Now, with that said, if these are closed end credit you have no legitimate permissible purpose (unless the accounts are delinquent) to be pulling a credit report for an annual review. See the Isaac-Gowen letter.

http://www.ftc.gov/os/statutes/fcra/gowen.shtm