Key Factors Disclosure with CRA Model

Answered by:

Question:

Regarding the FACT Act amendments to FCRA: Do we have to disclose the key factors along with the credit score on real estate loans if we use a CRA model and not our own?

Answer:

Yes. Section 212 is specific on this issue.

(A) INFORMATION REQUIRED UNDER SUBSECTION (f).--
(i) IN GENERAL.--A copy of the information identified in subsection (f) that was obtained from a consumer
reporting agency or was developed and used by the user of the information.

First published on BankersOnline.com 1/16/06