An LO sent out an AAN on a terminated file for "Insufficient Assets." -The applicant did not have enough of a down payment. BUT, he had a great credit score. The LO included in the Adverse Action Notice: "Your Credit Score," and the "Key factors that affected your credit score" (???) Why would this be on the AAN if the borrower had the credit, just not the assets? Is this an FCRA violation?

Mistake by the LO and a violation IMO. You're right, the credit score should be provided if it played a role in the denial; just routinely putting the score on every AAN whether it played a role in the denial or not is not compliant IMO.

Thank you-