We occasionally have foreign borrowers and can pull credit reports through one of the major credit reporting agencies. I'm thinking all the disclosures apply, since they still are a consumer. Your thoughts?

Bump

If you are in the US and pulling US reports then US regulations will apply. FCRA does not exclude coverage to non-US persons.

We are denying an applicant based on information obtained from a foreign credit report (Mexico), only the REG B section of the NOAT applies and not the FCRA section, correct?

Thanks

We also pulled a US credit report that was not used in the credit decision. Do we have to include the score and key factors on the NOAT from the US report because we got one even though it was not used to deny or do not include it?

Thanks,

If any person takes any adverse action with respect to any consumer that is based in whole or in part on any information contained in a consumer report,

The question is can you defend that it was not used?

Ok, we will report the info from the U.S. credit report on the NOAT. If we only had the Foreign credit report, no FCRA correct?

Thank You.