I am brand new to reviewing an Equipment Leasing department that pulls credit reports on individuals and I am wondering if I am looking / interpreting FCRA and ECOA correctly as I put together my review checklist. Is the following correct or any other information I may be missing.
FCRA: 1) Requires a consent from the individual to pull credit; 2) does not require the Credit Score Exception Notice to be provided to that individual; 3) no adverse action notice required even if the loan is denied based on credit report of individual
ECOA: 1) can following notification requirements for businesses as stated in 1002.9(a)(3)? 2) no adverse action notice required to the individual
Thanks for any insight.