Student applies with a co-signer for an education loan. The cosigner is declined for credit reasons. The student has no credit or a limited credit history. Should the letter to the student contain the FCRA verbiage? A vendor believes the student letter does not require the verbiage since the decline was based on the co-signers credit. We believe the credit report for the student was pulled and, even with no or limited credit history, was used in part in the decision and the verbiage should be included. Any thoughts? Thank you.

The lack of information in the report was used as the reason for denying the applicant, therefore the report was used in whole or in part in the credit decision and the disclosure should be made.

Thank you!! Have a great day!!