If we deny a customer a loan based on "excessive current obligations in relation to income", do we have to disclose their credit score to them on the adverse action notices?
Because on one end, it was based on income, not credit score. But on the other, their current obligations were determined based on the information pulled from their credit report.
Thoughts?

To answer your question, it really depends on who you ask.

The adverse action notice states that "Our decision was based in whole or in part on information from the credi reporting agency."

To be on the safe side, I'd disclose the credit reporting agency, because you can argue that information from the credit report was used to make your decision. It wasn't necessarily negative information (ie collections, delinquencies etc) but the notice doesn't state that it has to be negative.

Hope this helps.

In this case, we also disclose the credit score. Since the info was found on the credit report, we put the info.