(3) Conditions on use for adverse actions.
(A) In general. Except as provided in subparagraph (B), in using a consumer report for employment purposes, before taking any adverse action based in whole or in part on the report,......
Adverse action based on a credit report is required, as with lending decisions. If the decision was not based in whole or in part on the report, an adverse action notice is not required.
Spotty-credit? If you are using credit reports as part of your employment processes, there should only be pass or fail - if you act subjectively, you are digging yourself into a bad hole.
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