Our Mortgage Department is providing the following disclosure to borrowers:

"An investigation will be made as to the credit standing of all individuals seeking credit in this application. The nature and scope of any investigation will be furnished to you upon written request made within a reasonable period of time. In the event of denied credit due to an unfavorable consumer report, you will be advised of the identity of the Consumer Reporting Agency making such report and of right to request within sixty (60) days the reason for the adverse action, pursuant of section 615(b) of the Fair Credit Reporting Act."

Is this a required disclosure? I could not find this verbiage in the FCRA. Thanks!

The disclosure seems to be a mix of 615(a) and 615(b). The first two sentences seem to pertain to 615(b)(1), whereas the final sentence seems to apply to 615(a)(4)(A).

We include a variation of your disclosure in our adverse action notices. There's nothing wrong with including your disclosure, but I do not believe the first two sentences are necessary.

I am curious as to what others think as well.

After further investigation, I believe the notice may be a requirement of FCRA section 606(b). This section specifically deals with "investigative consumer reports", which are different from credit reports. Investigative consumer reports are more of a detailed background check and cannot be used for applications of credit. I believe they are used for things like insurance applications or employment background checks. If this is the case, I do not believe we are required to give this FCRA notice at all.