Im resurrecting this thread as I am having the same question and this was absolutely fantastic to read through.
I have always taken the conservative approach as well. I agree that it is required under FCRA if based on a consumer report - and is debatable whether required under Reg B. I believe that it would be required for a removed (denied) applicant for the reasons others have stated.
Has there been any updates to your opinions the last couple of years? Thanks gurus!
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.