The Fair Credit Reporting Act requires notice and disclosure duties when consumer reports or investigative consumer reports are used. An insurer must properly notify the applicant when an investigative report may be obtained and must provide required adverse-action notice if insurance is denied or affected based on report information. The applicant also has rights relating to the nature and scope of an investigative consumer report. However, the FCRA does not require the insurer to personally discuss every credit-history inconsistency with the applicant. The consumer’s dispute rights are generally exercised with the consumer reporting agency, not through an insurer’s mandatory discussion process. The Pennsylvania Title Insurance outline expressly includes the Fair Credit Reporting Act under federal regulation in the Insurance Regulation section.
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