Dan, thanks for your response. So do we agree that this sets up somewhat of a conflict with the way creditors were guided to disclose the FCRA adverse action notice when declinations were based on something other than credit? Maybe I'm over-thinking this but our lenders are starting to come with a lot of "what if's" here at the 11th hour.....!

Explain to them that regulations just don't mix together like a cake does. Small example: what might be a denial for Reg B could be an ANA for HMDA. And the list goes on.

We disclose the credit score on the AAN regardless of the denial reason. We do this because the credit score is used in our risk factor matrix we use in the approval process. The only time we would not disclose the score would be if the credit request was denied before a credit report was obtained.

Would this mean that we should also use code 9 for the name and version of the credit scoring model? Just want to make sure.

Reviving this thread to see if there was ever any final word on the question of whether the score is tied to the individual applicant or it is just the credit decision? So if we relied on the score for only the third co-applicant what do we report? That score in the applicant column or NA for applicant and co-applicant?

It may depend on if your first applicant for demographics happens to be an entity. In that instance, a validity error of 668 comes up if you place the credit score in placeholder 1. In instances where you have multiple applicants and rely on score{s} not based on applicant order, you should be able to successfully report what you actually used in placeholder 1.

So everyone is still in the camp (for an individual not an entity) of reporting the single score in placeholder 1 regardless of who it actually belongs to, correct? I have been in multiple camps on this topic as time has progressed.