I'm reviewing a Home Equity Line of Credit that was recently originated at our Bank. The borrowers are US citizens that are currently living in Canada, but the collateral was a NOO property in the US. We pulled a US credit report and used those scores for qualifying; however, we also pulled a Canadian credit report for the purpose of including any Canadian liabilities in the debt-to-income calculation. Do we need to send a RBP notice for the Canadian credit report if those scores were not a factor in the pricing or our credit decision?

Thanks for your input.

The FCRA is silent on foreign applicability.