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05-26-2016, 11:58 AM #1
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§*603. (f) The term “consumer reporting agency” means any person which, for
monetary fees, dues, or on a cooperative nonprofit basis, regularly engages
in whole or in part in the practice of assembling or evaluating consumer
credit information or other information on consumers for the purpose of
furnishing consumer reports to third parties, and which uses any means or
facility of interstate commerce for the purpose of preparing or furnishing
consumer reports
It is still a violation in the sense that they would be considered a consumer reporting agency under the above and we both know that there is no way they are compliant with the requirements that come with that."Nobody can make you feel inferior without your consent." -Eleanor Roosevelt
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05-26-2016, 12:26 PM #2
Reputation points: 1406
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An ISO be considered a "consumer reporting agency"? That would be a huge stretch based on the definition. In your example they bring a file with a "third party report". They didn't collect information about the consumer and prepare the report themselves. They got it from a CRA (Experian, TransUnion). They didn't get a fee for just delivering the report to underwriting. As long as they got permission to pull that consumer report, they are ok.
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