Must the user requirements for consumer report fraud alerts be followed for applications that are denied for reasons other than the alert itself? For instance, if the consumer report reflects a low credit score, but also has a fraud alert, do we have to contact the customer to verify identity under FCRA Section 605A?
In reading 605A.(h)(i) it says basically that we can't make a new loan, etc. unless we complete the verification of identity. It seems silent on what is required if an application is denied.
a