Here is a question that I wasn't able to find elsewhere in the threads. Can someone please assist?

Our loan software generates a FCRA notice with consumer loan documents. It says that our bank reports to a credit reporting agency in the top section of it, talks about accuracy of information, etc.

The bottom section contains a disclosure on information-sharing between affiliates, which may be checked or left blank as needed. Our bank does not share information between affiliates so this section does not apply and remains unchecked.

I have searched FCRA and do not see where this disclosure form is required. An employee at the loan software company says it is required, but she does not know why. Can anyone help us determine if it is indeed required?

Thank you!

This sounds like the affiliate sharing opt-out notice that is required by the FCRA. Our software also provides this notice but we do not use it as we have no affiliates.

If you should ever want to share with the affiliate, you would have to provide this opt-out notice.

Those are my thoughts as well. Thank you.