I think you have to look at the intent of the requirement. The consumer asks for information that you reviewed to come to your conclusion that doesn't agree with the consumer's claim. So if you have a photo of the consumer at the ATM, he's entitled to it. I can't see how photos of third parties will dispute the consumer's claim, so I don't think you'd be revealing them. Notes from a phone conversation that helped with the decision? Yes, I think you'd want to provide that information, too.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8