Good Morning! I just stumbled across something in an adverse action audit and wanted to get some feedback.
We currently use CBC Innovis to pull credit bureau information in relation to our mortgage products. This is a tri-merge report but I realized today, it's also pulling in lien and judgment information from Lexis Nexis Risk Solutions. In this particular case, the information reported by Lexis Nexis was the reason for our adverse action. So, when completing the adverse action form, I believe Lexis Nexis needs to be the CRA listed under "Our credit decision was based in whole or in part on information obtained in a report from the consumer reporting agency..." Then as far as the credit score information, we would list the middle score per our procedures.
Does this sound correct or am I way off base here? Thanks in advance!