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#2244911 - 10/30/20 10:39 PM FCRA Notice FICO Liquid Credit Score
IGaev Offline
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Joined: Dec 2016
Posts: 55
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!!

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#2244912 - 10/30/20 11:08 PM Re: FCRA Notice FICO Liquid Credit Score IGaev
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
The FICO LiquidCredit Small Business Scoring Service (The FICO SBSS Score) while it may take into consideration the credit history of the principals of the business, it is not a "consumer credit report".
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