NAA/NHMC Guidance on “Credit Score” Disclosure Effective July 21

July 19, 2011 at 8:55 pm Leave a comment

This important information is in the latest issue of NAA’s AIMS Update (you can now find AIMS Updates in the “News” section of PTAA’s website):

NAA/NMHC have issued a new members-only guidance document to help member firms understand new “credit score” disclosures that go into effect on July 21.  As a result of a provision in last year’s Dodd-Frank Wall Street Reform law (P.L. 111-203), a firm using a “credit score” in the rental screening process that takes an adverse action against a rental applicant may have a new disclosure obligation.

If you or your resident screening service provider use a credit score and take an adverse action, you must comply with this new notice requirement.  Importantly, if you or your resident screening company do not use a credit score as defined, but use a scoring model specific to the rental decision (i.e., one not used in the loan process), then it is likely that you will have no additional notice obligations.

NAA/NMHC’s guidance highlights the key elements of the new credit score disclosure obligations.  NAA/NMHC encourage you to discuss this new rule with your provider and counsel to determine applicability to your specific rental screening process.

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Entry filed under: NAA.

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