The credit card department recently pulled a refresh on all of the consumer accounts for a current credit score. They have decided to close some of these accounts because the credit score falls below the bank's allowed threshold. I told them that since they were taking adverse action based on a credit score they had to disclose the score, the key factors, etc required by 609(f)(1) of the FCRA.
The credit card department is telling me this is a problem, as they don't get an actual credit report. They just get the score, so wouldn't be able to give key factors, or even specific reasons as to why adverse action was taken. Just that the score was too low.
I think this is a problem! Any advice?