The credit score disclosure notice applies to consumer applications that are secured by residential real property of one to four units. This disclosure must be furnished by a lender who makes or arranges loans and who uses a consumer credit score, in connection with an application initiated or sought by a consumer for a closed-end loan or the establishment of an open-end loan. Under the FACT Act, the notice appears to be required for all applications, not just applications that are approved or denied.
The notice contains standard language found in the FACT Act; additionally, the notice requires the disclosure of the credit score, key factors that affected the score, and the credit bureau that provided the score.
Under the FACT Act, if a lender uses a credit score other than a credit score provided by a consumer reporting agency, the lender may satisfy the obligation to provide a credit score by disclosing a credit score and associated key factors supplied by a consumer reporting agency. Therefore, all disclosure will be based on the credit bureau score.