We have a partner that utilizes a platform to perform ID check, fraud checks, etc. If the applicant fails the fraud check or ID check, the partner denies the application and sends an AAN "unable to verify identity". This has resulted in a number of complaints and customer confusion (ie. borrowers sending in W2s, drivers licenses, etc.)

Does anyone have a different approach that they have seen provide more clarity in these situations? The partner does not have a manual UW process and the fraud fail or ID fail is a hard stop for them.

Are they providing the required FCRA denial information along with the Regulation B denial? If they are "using a platform" how is this not an investigative or consumer report?

Yes, they are utilizing the model forms/language. The issue seems to be circling around the reason for denial. I am hoping someone has maybe some more "definitive" language that can be used so applicants don't take it as a request to provide identifying information.

Well, I think you would need to tell us more of what you are talking about. They give you a driver's license and the platform comes back and says it has never been issued? What do you mean unable to verify identity? What does that mean in this situation? What is a fraud check?