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.