Does anyone out there use Fair, Isaac for scoring consumer loans? If so, how are you handling the Adverse Action requirements that have come to light from the recent FTC opinion letter? The FI adverse action process appears to be an "all or nothing" situation; either all co-applicants recieve a letter with the FCRA disclosures even if their credit did not impact the decsion, or no one gets a letter, even if their credit did impact it. To do otherwise seems to involve a great deal of manual intervention, which we are trying to avoid by using this automated process. If we can't fix this, I would rather err om the side of providing a FCRA notice if it isn't needed than not providing one if it is. Any thoughts?
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