I agree with Randy and your auditors. Using outstanding debt from a credit report to calculate the DTI is, in fact, using "in whole or in part on any information contained in a consumer report" as outlined in the FACT Act.
For a citation, you need to look at the FACT Act. Specifically, look at 1681m here: https://uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title15-chapter41-subchapter3&edition=prelim
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com