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#2228858 - 01/13/20 02:48 PM Action Taken-Third Party Information
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,109
In the mountains
What are some examples of third parties in FCRA for providing adverse action notices:

• Consumer credit is denied or a charge for credit increased based on information obtained from third parties other than consumer reporting agencies bearing upon the consumer’s creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living;

I just reviewed an Adverse Action notice where this was included but the reason for the decline is that the applicant is not a U.S. Citizen or Lawful Permanent Resident of 10 years or without expiration. All the file has as documentation is that the applicant acknowledged he is not a citizen and the temporary drivers license he has would be expiring in less than a year from the date of application (which prompted asking about citizenship). Temporary drivers licenses are issued in this state for persons with a legal temporary legal presence.

Does the temporary DL qualify as information from a third party?
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#2228859 - 01/13/20 02:56 PM Re: Action Taken-Third Party Information Likes to Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
No - the applicant provided it.

That would be used if you, for example, contacted their landlord and received information that the borrower was chronically late on their rent payments.
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