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Misleading Adverse Action Notice?w
Answer by Andy Zavoina and Richard Insley, BOL Gurus

Question: If an adverse action is for reasons other than information from a reporting agency, would a default statement that "The consumer reporting agency contacted that provided information that influenced our decision in whole or in part was:....." be misleading.

Answer by Andy Zavoina:
BIO AND CONTACT INFO
Yes.

If a CRA was not used, do not mark the box. Otherwise you are sending the customer there in an effort to correct their report when in fact it was not a contributing factor in your decision.

Answer by Richard Insley:
BIO AND CONTACT INFO
I'd take it a step further and call it a violation.

First published on BankersOnline.com 8/11/03







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