In light of a specific instance brought to our attention, we will be making a slight modification to our Statement of Credit Denial, Termination or Change (Cx15858). Per 12 C.F.R. § 1002.9(a)(2)(ii), when there is a denial of credit a notification must be given to the applicant. Docutech uses our copy of the model form C-1 (our Cx15858) to give notification of denial of credit. Form C-1 instructs that if the credit decision was made based in whole or in part on information that has been obtained from an outside source, then Part II should be completed. Occasionally clients may encounter a situation where the borrower is denied credit because they do not have a credit score, or no credit file. Since the credit denial was based on information from the credit reporting agency that the applicant did not have a credit score or there was no credit file, Part II should still be completed.
Consequently, we are updating Cx15858 to fill out Part II, including the checkbox and credit reporting agency’s information, when the field Credit Report Used to Grant Credit (H-3/H-5) (49608) is set to Yes. This ensures that Part II will be completed even when the borrower has no credit score or credit file.
This change will be in effect on April 26, 2016. If you have any questions or concerns about this change, please contact Client Support at 1.800.497.3584.