Are creditors who grant trade credit and use personal credit bureau reports in their decision-making required to comply with the changes to section 615A of the Fair Credit Reporting Act (FCRA)?

Yes. The amendment requires any person who takes "adverse action" with respect to any consumer based on information contained in a consumer credit report to provide the consumer with:

  • Written or electronic disclosure of the numerical credit score;
  • The range of possible scores;
  • Factors that adversely affected the score, which should be ranked in order of importance. The number of factors should not exceed four, unless the number of credit inquiries is a factor and not reflected in the top four;
  • The date the credit score was created;
  • The name of the person or entity that provided the credit score or file.

This would apply to a trade credit situation in which a potential customer’s personal credit score is used to evaluate an application for trade credit.

The proposed changes took effect on July 21, 2011.

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