Where an individual applies for business credit, the business has gross revenues under $1MM, a consumer report is obtained, and the application is denied, must the lender disclose the key factors that impacted the credit score if they provide a written AAN to the applicant?
1002.9(a) doesn’t require it, but the model form includes credit score info. Commentary to 1002.9(b)(2) #9 seems to indicate that the key factors impacting the credit score should be stated, but it specifically references “consumer” when discussing the topic. To further complicate the issues, Reg. B defines consumer credit as credit extended to a natural person primarily for personal, family, or household purposes. FCRA, on the other hand, defines consumer as a natural person.
I’m leaning toward “either way is compliant”, but I’d like some intelligent thoughts.
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