however, that the FCRA only applies to consumer transactions, so adverse action notices are not required under the FCRA for business transactions. TABLE 1 Regulation B FCRA (Consumer) (Consumer and Business) A creditor must provide a notice if it has: For a covered transaction, a person must provide notice if: Taken adverse action on a completed Adverse action was taken based in credit application; whole or in part on information in a consumer report; Taken adverse action on an incomplete credit application; Consumer credit is denied or a charge for credit increased based on Taken adverse action on an existing information obtained from third credit account; or parties other than consumer reporting Made a counteroffer to an application agencies bearing upon the consumer’s for credit and the applicant does not creditworthiness, credit standing, accept the counteroffer: credit capacity, character, general reputation, personal characteristics, or Notice is not required if: mode of living; or The transaction does not involve Adverse action was taken based on credit; information furnished by a corporate affiliate of the person taking the A credit applicant accepts a action counteroffer; A credit applicant expressly withdraws an application; or The creditor approves a credit application and both parties expect that the applicant will inquire about its status, but the applicant does not inquire within 30 days after application (the approved application is treated as withdrawn)
however, that the FCRA only applies to consumer transactions, so adverse action notices are not required under the FCRA for business transactions. TABLE 1 Regulation B (Consumer and Business) FCRA (Consumer) A creditor must provide a notice if it has: For a covered transaction, a person must provide notice if: Taken adverse action on a completed credit application; Taken adverse action on an incomplete credit application; Taken adverse action on an existing credit account; or Made a counteroffer to an application for credit and the applicant does not accept the counteroffer: Notice is not required if: The transaction does not involve credit; A credit applicant accepts a counteroffer; A credit applicant expressly withdraws an application; or The creditor approves a credit application and both parties expect that the applicant will inquire about its status, but the applicant does not inquire within 30 days after application (the approved application is treated as withdrawn) Adverse action was taken based in whole or in part on information in a consumer report; Consumer credit is denied or a charge for credit increased based on information obtained from third parties other than consumer reporting agencies bearing upon the consumer’s creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living; or Adverse action was taken based on information furnished by a corporate affiliate of the person taking the action
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