Due to a system glitch, the key factors are not coming out on the credit report, only the credit score. For the notice of adverse action, is it okay to include only the score without the factors?

Thank you

Who's system glitch?

The credit reporting agency changed the score model ahead of the scheduled date and our third-party vendor was not advised to update the score model reason codes.

Thank you

Then this appears to be a problem that has fallen into your lap, if the CRA actually provided you the reasons and you need to fix it and reissue.

If we reissue, we would have to pull another credit report to get the reasons. I'll check with them to see what they can do, We don't want another inquiry showing on the customers credit report. It was their error for updating it ahead of schedule when we were not ready.

Thank You

It was their error for updating it ahead of schedule

From 605(d)

(2) Key factor in credit score information. Any consumer reporting agency that furnishes a consumer report that contains any credit score or any other risk score or predictor on any consumer shall include in the report a clear and conspicuous statement that a key factor (as defined in section 609(f)(2)(B)) that adversely affected such score or predictor was the number of enquiries, if such a predictor was in fact a key factor that adversely affected such score. This paragraph shall not apply to a check services company, acting as such, which issues authorizations for the purpose of approving or processing negotiable instruments, electronic fund transfers, or similar methods of payments, but only to the extent that such company is engaged in such activities.

I would insist the CRA provide you revised reports at no cost and no affect on the consumer's score. I might even be inclined to push them for a refund on all non-compliant reports they provided you.