Borrower Denied Credit for Insufficient Income

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Question:

If a borrower was denied credit for insufficient income (non credit score related), does the credit /score disclosure need to be included with the denial letter?

Answer:

Typically not. The disclosure of the numerical credit score as defined in section 609(f)(2)(A) is disclosed when the bank takes any adverse action based in whole or in part on any information in a consumer report. If you used the report in some manner to calculate "insufficient income" then it would be required. If the report was not used, the disclosure regarding the credit reporting agency would also not be appropriate.