Key Factors on Credit Score Dislcoures

For our mortgage loans we give the Credit Score Disclosure Exception instead of the Risk Based Pricing Disclosure. I understand that 4 key factors are listed and the fifth factor can only be "Number of recent inquiries affected the credit score" The problem is the credit report may list four factors and in the 5th spot list "08 - Too many inquiries last 12 months". Our loan operations area has been listing this on the Credit Score Disclosure Exception as the 5th factor...would that be ok or am I being to picky? The credit report may also list "08..." as the 2nd or 3rd factor on another report.

They are the same thing. If that is number 2 or 3, then you are not going to have 5 reasons.