Fair Credit Reporting: 8.5.2.4 Credit Scoring Information
The Dodd-Frank Act added a requirement that users include in the adverse action notice the actual credit score used in making the decision.125 This provision applies to any user required to give an adverse action notice, which should include creditors, insurers, and others. However, it uses a definition of a credit score that is limited to scores for “predicting credit behaviors.”126 Thus, it is unclear whether the specialized scores used by insurers and others must be disclosed.