Answer:
Answer by Andy Zavoina:
No. You would disclose information from a third party only when that information contributed to the denial.
Answer:
Answer by Lucy Griffin:
Ditto. For some time, many examiners claimed that if you had pulled a credit bureau report and denied credit for other reasons, you still had to give the customer the FCRA notice. This is simply wrong. The FCRA notice is triggered, not by pulling the credit report, but by using information in the report to make the denial. Giving the FCRA notice when the report did not contribute to the denial is not only misleading and confusing to the customer but also frustrating to the credit bureau that may be the target of questions and requests for free copies of the report.
First published on BankersOnline.com 8/11/03
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