I remember coming across some conflicting information on which company or agency to list in the AAN when you order the credit report through a different vendor than the Agency. In other words, using Model Form C-1 in Reg. B, who do you list in the part under "Our credit decision was based in whole or in part on information obtained in a report from the consumer reporting agency listed below?" And, then who do you list under the part that says "If you have any questions regarding your credit score, you should contact [entity that provided the credit score] at?"

Let's say you order the credit report from Credit Plus and you use a tri-merge report. Do you list TransUnion, Experian, and Equifax in both sections, or Credit Plus in both sections, or Credit Plus for one part and T/E/E for the other?

I'm not seeing the second part you're referencing on our AANs, but we list the "Credit Plus" equivalent on Page 1.

You report the company that you received the (tri-merge) credit report from, e.g. Credit Plus - the same one you signed the contract with - the same one that you pay. Equifax, experian and trans union would be customers of Credit Plus - not you.

Part 2 - you report the company who provided the credit score. Usually they provide only 1 score and identify it in the report.

Thank for the feedback. Rocky P - So, this would be Credit Plus again basically from what you are saying for Part 2?

The report back from the Tri-merge should indicate whose score they are using, and the ranges (they are different).
e.g.
generic FICO - 300-850
Equifax - 280-850
Trans Union - 300-850
Experian - 360-840
Vantage - 501-990

If they provide 3 scores - I would list all 3 Just 1 needed - refer to Randy's e-mail below.

Disclosing all is optional, but not really encouraged:

Multiple Scores
Some creditors may obtain multiple credit scores from consumer reporting agencies in connection with their underwriting processes. A creditor may use one or more of those scores in taking adverse action. Section 1100F of the Dodd-Frank Act only requires a person to disclose a single credit score used in taking adverse action.

When a creditor obtains multiple scores but only uses one in making the decision, the creditor must disclose the credit score that it used. Commenters asked what credit score or scores creditors should disclose when creditors use multiple scores in taking adverse action, for example, from different consumer reporting agencies. Section 1100F of the Dodd-Frank Act does not specify what credit score should be disclosed in such cases, but only requires a person to disclose a single credit score that is used by the person in making the credit decision. A creditor would comply with the statute by disclosing any of the credit scores that it used. The Board expects that creditors will have policies and procedures to determine which of the multiple credit scores was used in taking adverse action. For instance, a creditor could have policies and procedures specifying that: (1) when the creditor obtains or creates multiple credit scores but only uses one of those credit scores in taking adverse action, for example, by using the low, middle, high, or most recent score, the creditor would disclose that credit score and information relating to that credit score; and (2) when a creditor uses multiple credit scores in taking adverse action, for example, by computing the average of all the credit obtained, the creditor would disclose any one of those credit scores and information relating to the credit score.

Because credit scoring models may differ considerably in nature and the range of scores used, consumers would not necessarily benefit if they receive and try to compare multiple scores. Disclosing multiple credit scores could confuse consumers who do not understand the differences, which might lessen the value of the section 1100F disclosures. Moreover, section 1078(a) of the Dodd-Frank Act requires the Consumer Financial Protection Bureau (CFPB) to conduct a study of the different credit scoring systems, and whether these variations disadvantage consumers. The CFPB’s study might develop a record that could serve as the basis for reconsidering this issue in a future rulemaking.

So, embedded in the scores language, you would have the model being used, i.e. Equifax, Experian, etc.; however, in the part of Model Form C-1 where you list respond to the following: "If you have any questions regarding your credit score, you should contact [entity that provided the credit score] at:

Address:

[Toll-free] Telephone number: ____"

, then you would use the company that you actually ordered the report from, i.e Credit Plus? Or, should the word Experian or Equifax not show up anywhere in the form if you did not directly order from said CRA?

The more I read on it, I come to a conclusion and then get thrown off again. Is Credit Plus considered a "Consumer Reporting Agency? If so, then it would seem like the lender would list the information of Credit Plus in both places. The Multiple Score guidance throws me off, because you often do get multiple scores from Credit Plus, i.e Experian, TransUnion, Equifax. So, even if you get multiple scores, they are still coming from one CRA (Credit Plus) if that is the correct interpretation.

They are definitely a CRA. See reference below. I would agree with your interpretation - Credit Plus is providing, and you are paying them for, the report and/or credit score.

Fair Credit Reporting Act, 15 U.S.C. 1681a(f).
(f) The term “consumer reporting agency” means any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties, and which uses any means or facility of interstate commerce for the purpose of preparing or furnishing consumer reports.

Credit Plus purchases their information from the big 3. They are a reseller and resellers are CRAs. See FCRA section 603(u).

Thank you, that seals the deal.

Since, in this case Credit Plus, is a reseller and defined as a CRA; isn't it true that they do not fit the definition of §615(a)(3)(a):

the name, address, and telephone number of the consumer reporting agency (including a toll-free telephone number established by the agency if the agency compiles and maintains files on consumers on a nationwide basis) that furnished the report to the person; and

1681(a) defines a CRA that compiles and maintains files on consumers on a nationwide basis:
(p)Consumer Reporting Agency That Compiles and Maintains Files on Consumers on a Nationwide Basis.—The term “consumer reporting agency that compiles and maintains files on consumers on a nationwide basis” means a consumer reporting agency that regularly engages in the practice of assembling or evaluating, and maintaining, for the purpose of furnishing consumer reports to third parties bearing on a consumer’s credit worthiness, credit standing, or credit capacity, each of the following regarding consumers residing nationwide:
(1) Public record information.
(2) Credit account information from persons who furnish that information regularly and in the ordinary course of business.

(including a toll-free telephone number established by the agency if the agency compiles and maintains files on consumers on a nationwide basis)

That means you are only required to include a toll-free number if they are a nationwide CRA. That has nothing to do with the rest of the requirement.

Thank you rlcarey!