If a bank does not have a minimum credit score requirement and they themselves do not report to credit reporting agencies, it that enough to prove that the bank did not "use the score in taking adverse action"? And, let me add this - on credit approval forms, there is a place where the credit score and date the score was obtained is included.

In my opinion, if you are obtaining a credit report that includes a score and there's evidence elsewhere in your forms where a credit score is asked for, then it's being used in some way, so you should be including the credit score information (required by Dodd Frank in July 2011) on your adverse action notices.

Thoughts?

I agree...it's hard to imagine that if you have access to the score, that it doesn't factor in your decision in some way.

Besides...you use the report in general, so you are considering the factors that make up the score. Good and Bad.

I agree...if it is on the report it is pretty hard to deny you don't use it in your decision. If you truly do not use the score, ask your vendor to remove the score from the reports.