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Does a bank need to provide a risk-based pricing notice if it does not use a customer's credit score?

My bank is looking at offering a second mortgage product based on down payment, debt ratios, etc. The bank pulls the credit report, which includes a credit score, but only uses the report to verify the debt the borrower has listed. The bank does not use the credit score. Must the bank provide a risk-based pricing notice even though it did not use it?

The bank need not issue a risk-based pricing notice unless you “USE” the credit score in setting the material terms of credit. This is from the ABA Staff Analysis of the final rule:

If the credit score was not used in the decision, does the creditor have to provide the credit score?

No. The notice need only be provided if a credit score was used in setting the material terms of credit. However, examiners may question why a bank pulls credit scores if it is not for purposes of determining the price. In addition, even if the credit score was not a significant factor in setting the material terms of credit but was a factor, the creditor must provide the credit score notice. (September 2017)

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