We have covered in the past on whether the the FCRA box in a denial notice should be checked if the decision was based solely on “value or type of collateral†as that decision wouldn't be based in whole or in part from information in a consumer report. But what of other reasons, such as a lack of or inadequate down payment, or income, where information in the report didn’t influence the adverse decision. In the risked-based pricing regulations, below, it states “…credit score proxy method generally would eliminate the influence of variables that are not derived from information in a consumer report, such as the consumer’s income, the term of the loan, or the amount of any down payment.. …â€. Do you think the FCRA box should also not be denoted when the denial reasons solely are due to the other above reasons?
https://www.govinfo.gov/content/pkg/FR-2010-01-15/pdf/E9-30678.pdf