FCRA - If we are declining an application based on a low appraisal, should we check the FCRA box that information was used from an outside source other than a consumer reporting agency?

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Q:  If we are declining an application based on a low appraisal, should we check the FCRA box that information was used from an outside source other than a consumer reporting agency?

A:  No.  The FCRA requirements that apply to the statement of "Our credit decision was based in whole or in part on information obtained from an affiliate or from an outside source other than a consumer reporting agency" are contained in Section 615 of the Act.  Therein, the general rule is that this applies to information "bearing upon the consumer's credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living."  With that in mind, the adverse action reason related to a low appraisal would not apply to this statement and you would not check the FCRA box.

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