Are we required to report ALL credit information on denied applications?

Reporting of credit information such as credit score, DTI, CLTV and AUS data points is required on denied applications if applicable. Some confusion exists with regard to whether or not to report “all” fields.

The issue seems to be in the interpretation of reporting “the credit score relied on in making the credit decision” or similar references to DTI and CLTV. Many lenders have historically ONLY reported the credit score, DTI or CLTV based on the denial reason – meaning if the application was denied for DTI, they reported ONLY DTI, but not other credit fields. It’s important to remember that the regulation additionally has specific language that indicates that credit information is required to be reported “even if it was a dispositive factor” – meaning that if your underwriting criteria for a specific loan program considers credit score, DTI and CLTV, you must report all three fields of data even if the denial reason related to only one factor. From the HMDA Guide:

A Financial Institution relied on a credit score in making the credit decision if the credit score was a factor in the credit decision, even if it was not a dispositive factor. For example, if a credit score was one of multiple factors in a Financial Institution’s credit decision, the Financial Institution relied on the credit score even if the Financial Institution denied the Application because one or more underwriting requirements other than the credit score were not satisfied. Comment 4(a)(15)-1.