Question:
This question is in regard to Consumer Loan applications (such as car/boat/RV loans and personal loans and non-dwellings related). Our Consumer Loan Division uses the credit score from a credit bureau as one of the input attributes to decision (approve, decline, or counter offer) an application. The Consumer Loan does not use Risk-Based-Pricing - in other words, for those applications that are approved, they all receive the SAME pricing terms (e.g. same interest rate). For declines, we disclose to the customers the Credit Score Disclosure that includes the 5 elements - (1) The actual numerical score used in the adverse decision; 2) The range of possible scores under the model used; 3) All key factors that adversely affected the credit score; 4) date score was extracted; and 5) the bureau used and contact as modeled after form C5. Our question is for those applications that are approved. Do we need to disclose the Credit Score Info? The argument for NOT needing the Credit Score Disclosure or RBP are these customers are approved and do not receive unfavorable terms. Should we disclose Credit Score Info even for applications that are approved (same as what we do for declines)?