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"XYZ Data" on Adverse Action Notice

Question: 
I have a client (a lender) who orders their credit reports from "XYZ Data" and when a loan is declined, they list Equifax on their Adverse Action Notice (with appropriate address and phone number) and they have now been told that because "XYZ Data" is considered a reseller of credit under the FCRA 603(u) that they should also list XYZ Data (along with its name and telephone number) on the Adverse Action Notice. Is this true?
Answer: 

by Dan Persfull:

Yes, XYZ Data is the Consumer Reporting Agency you obtained your information from.

Answer: 

by David Dickinson:

615(a)(3)(A) of the FCRA requires users to disclose:

the name, address, and telephone number of the consumer reporting agency (including a toll-free telephone number established by the agency if the agency compiles and maintains files on consumers on a nationwide basis) that furnished the report to the person;

I agree with Dan that XYZ Data is the furnisher of the report, not Equifax.

First published on 08/25/2019

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