I have an unusual denial situation. A customer came in and was denied based on their inability to qualify for the type of credit requested. Their credit report was pulled; however, it in no way affected the credit decision. Therefore, I believe I have a legitamite reason to not include the language in the adverse action form,”our credit decision was based in whole or in part on information obtained in a report from the conusmer reporting agency…..” However, my question surrounds the additional FCRA paragraph indicating the credit decision was based in whole or in part on information we obtained form an affiliate or from an outside source other than a consumer reporting agency. Since the reason for denial was based soley on information from the credit application, would the credit application be considered an “outside source” and require the additional language in the Adverse Action Notice. I don’t think it would, but I would like your opinion. Thanks for your help.
No it would not. An outside source would be something like an appraisal or a survey etc. An application is not considered an outside source.
You would not need to fill out the credit score disclosure information either, if none of your denial reasons came from the credit report or if your decision was not influenced by the credit report.