A lender declines a $265,000 application after reading a report from a specialty consumer reporting agency that tracks 24 months of rental payment history. If the denial is based in whole or part on that specialty report, which reporting agency must the FCRA adverse-action notice identify?
Correct Answer
A) Identify the specialty agency that supplied the report, including its name, address and telephone number
A. Identify the specialty agency whose report contributed to the adverse action. The triggering fact is reliance, in whole or in part, on that consumer report. Agency contact details direct the consumer to the actual report source. A specialty agency does not disappear from the notice merely because it is not one of the major nationwide bureaus. Scope and exceptions: A toll-free number is required under the cited clause when the agency maintains nationwide consumer files. The full notice has additional duties; this question tests agency identification only. Source: 15 USC 1681m(a)(3)(A), 2024 codified edition — https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapIII-sec1681m.htm
Why This Is the Correct Answer
A. Identify the specialty agency whose report contributed to the adverse action. The triggering fact is reliance, in whole or in part, on that consumer report. Agency contact details direct the consumer to the actual report source. A specialty agency does not disappear from the notice merely because it is not one of the major nationwide bureaus. Scope and exceptions: A toll-free number is required under the cited clause when the agency maintains nationwide consumer files. The full notice has additional duties; this question tests agency identification only.
Why the Other Options Are Wrong
Option B: Name no agency at all, because the decline rested on the debt ratio
It contradicts the stated reliance on the specialty report.
Option C: Name the 3 nationwide bureaus, since they are the reporting agencies
Naming unrelated nationwide bureaus does not identify this report’s supplier.
Option D: Name the agency only where the applicant asks within 60 days of notice
The identification duty is not conditional on a later consumer request.
Exam Tip
Identify the actual report supplier, and do not apply a conditional notice detail universally.
More Federal Laws Questions
Before the team acts on a production meeting, a training manager must address SCRA Interest Rate Cap. Which response is most defensible?
A team member asks about RESPA Kickbacks and Referrals in an investor-delivery review while trying to confirm the rule-based response. Which response should the loan team use?
During a disclosure desk review, the loan team encounters an RESPA Servicing Transfer issue. Which response should avoid a shortcut that would misapply the rule?
A disciplinary-risk review raises a question about TILA APR and finance-charge rules. Which action should the renewal specialist recommend?
An MLO is reviewing procedures for a case where a compliance analyst asks why covered mortgage application data is collected. What is the proper handling?
A consumer complaint response raises a question about GLBA privacy requirements. Which action should the state compliance officer recommend?
Before the team acts on a branch training session, a policy analyst must address RESPA Servicing Transfer Notice. Which response is most defensible?
A training manager is resolving RESPA Referral Fees during an internal audit sample. Which action best fits the rule?
An operations lead is resolving ECOA Prohibited Discrimination Bases during a loan-team coaching session. Which action best fits the rule?
In a file escalation meeting, a disclosure specialist sees facts tied to TILA Closing Disclosure. What should the file reflect?
People Also Study
General Mortgage Knowledge
20% of exam
Mortgage Loan Origination Activities
27% of exam
Ethics, Fraud & Consumer Protection
18% of exam
Uniform State Test Content
11% of exam
Related Study Resources
Previous Question
Before the team acts on a branch training session, a quality-control reviewer must address TILA HPML Appraisal Requirements. Which response is most defensible?
Next Question
The supervisor compares the file facts with RESPA Kickbacks and Referrals during a new-hire scenario. Which conclusion is accurate?