We're implementing FICO Liquid Credit Score for small business credits and I was hoping to get your perspectives. As we know, under FCRA 615(a) if we take adverse action with respect to any consumer based in whole or in part on information contained in a a consumer report, we must disclose the numerical score along with other disclosures.
It's my understanding the FICO Liquid Credit Score combines business and individuals' performance (to include individuals' credit scores) to arrive at a composite score.
I don't believe that FICO Liquid Credit Score constitutes a consumer report; however, based on the fact that it considers individuals' credit scores, I am trying to discern whether it would trigger the FCRA disclosure when he applicant is a sole proprietor or when we have a permissible purpose to pull credit for the principals of a business entity.
Thank you in advance and I welcome your thoughts!!