The denial eltter has three boxes to check for FCRA (not reg B, in this instance)
The first box is checked when the credit report is used.
The second box is checked in cases where we obtained info, relating to credit, but from an outside source, for example, landlord gives info about payment history. There is a third box That says" our credit decision was based in whole or in part on:
When would you check and use this box. When we have collateral issues, income is insufficient/ When would this box be left blank.