Okay, I am looking at the FCRA and see in Section 615 about reporting the name, address, and phone number of the credit reporting agency (Informative Research). Our mortgage department uses a service provider and is disclosing this service provider's name on the AA notice, since this is where they got the credit report. My thinking is we should really need to report the actual CRA (Trans Union, etc.) info since they are the actual credit reporting agency, not the service provider who gathers, formats and provides the report from the info IT got from the CRA. Is my thinking correct, or am I losing it since it is Friday??

We started wondering the same thing when our local service provider had a name change and changed their address as well and so our information did not match up.

Here is something else I thought of in this issue-when we provide the mortgage application credit score disclosure, we reference the big 3 credit bureaus for basically the same reason that we should on the AA notice, which makes me think my observation may be close to correct? Do you also disclose the big 3 on that disclosure or were you listing the service provider whose name changed?

For FCRA I would think you should provide the the name and address of one of the 3 CRA's. If the loan was denied because of information in the CR, the Third Party Provider is not going to be the one to contact in the event that the informantion is incorrect, the Credit Bureau would need to be contacted.

IMHO, you would provide the required information from the bureau/agency that you ordered the report from. They were the ones you contracted and they were the ones you received the report from. If there was an error, the applicant would contact them for correction. They (by providing the information to you) become credit reporting agencies.

But if something needed to be changed in the report itself, the service provider would not be able to change the data, only the true credit reporting agency (still thinking the big 3). Also, when the bank/mort. co uses the service provider, we are that company's customer and they would have no obligation to provide a free copy to the denied customer under the FCRA like the true credit reporting agency, right? Devil's advocate just covering all angles....

Good points, but again IMHO, the bank did not contract with the "big 3" they contracted with (for example Credco), or one of the other providers/resellers. The bank needs to refer the customer to where "THEY - the bank" got the information that was used in the decision making. The bank did not get the info directly from Equifax, Experian or Trans Union, but from the 3rd party service provider, who used information obtained from E, E & TU.

There are mechanisms in place for the applicant to get a copy of the report that was used in underwriting, by asking the provider for it.

If the bank used a tri-merge, writing to one of the Big 3 will not get them the report that was used, and I'm sure that none of the Big 3 would even release it as the bank never ordered a report from them to John Doe. It was ordered from a reseller.