2 questions here:
Looking at a credit bureau with a key factor "too many inquiries in the last 12 months", would this be considered a 5th key factor?
Also if the credit bureau states "inquires did impact the credit score and, for models that indicate it, no derogatory information was found on the file" would this be considered a 5th key factor?

Commentary to 1002.9(c)-9:

"The FCRA also requires a creditor to disclose, as applicable, a credit score it used in taking adverse action along with related information, including up to four key factors that adversely affected the consumer's credit score (or up to five factors if the number of inquiries made with respect to that consumer report is a key factor)."

We are in the process of changing our loan platform system and to process an NOAT, we select the key factors from a drop down menu; the only option for the 5th factor is "Number of recent inquiries".

If the 5th factor on the credit report is "Inquiries impacted the credit score" or "Number of inquiries adversely affected the score, but not significantly", is this the same as "Number of recent inquiries"? We are not allowed to type in the 5th factor to what it is on the credit report. Is "Number of recent inquiries" the general use for these factors? or do we not input the 5th factor because it does not read the same even though it's listed on the credit report.

Thanks.

In my opinion, both of the examples you gave fall under "number of recent inquiries". As always, if you're going to list a fifth factor then you must do so consistently for all applicants in which one of the above reasons is listed on the credit bureau report. Additionally, your procedures should reflect both of the above reasons so it's clear to a third-party that you are consistent in your practices.