k) Adverse Action
(1) Actions included. The term “adverse action”
(A) has the same meaning as in section 701(d)(6) of the Equal
Credit Opportunity Act; and
(i) a denial or cancellation of, an increase in any charge for,
or a reduction or other adverse or unfavorable change in
the terms of coverage or amount of, any insurance, existing
or applied for, in connection with the underwriting of
(ii) a denial of employment or any other decision for employment
purposes that adversely affects any current or
Would your decision not to interview the individual be an "adverse action" pursuant to this section? I think so.
The purpose of the notice is to make certain the consumer knows that something said by a CRA has had an impact on his life and, if what's being said is wrong, the chance to correct it. If you don't tell them, they may never know what the problem is.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.