If we are accessing our credit reports through CBC/Innovis for Experian, TransUnion or Exquifax, whose name and contact information do we put on the adverse action notice for the "Consumer Reporting Agency"?

If we list CBC/Innovis, do we also need to list the Repository somewhere on the form (Exp, TU or Eqfx)?

Section 615 of the FCRA requires that we provide to the consumer the name, address, phone number of the consumer reporting agency "that furnished the credit report to the bank".

In my opinion, CBCInnovis (which meets the definition of a consumer reporting agency (CRA) furnished the report and should be the entity listed in the FCRA portion of the report - "our credit decision was based in part on information obtained from the consumer reporting agency listed below" - rather than Transunion, Experion and/or Equifax.

However, in the preamble to the new Reg V/B credit scoring rule, under the heading of Multiple Scores, the guidance essentially states that when multiple scores are obtained the creditor should rely upon the credit score that it used in reaching its decision to deny credit. If there were three scores listed on the tri-merged report you would list the name of the entity (EquiFax, TU or Experion) whose score you relied upon in making your underwriting determination if the score played a role in the denial since you are required to list the "name of the person or entity that provided the credit score" instead of the entity that provided the report.