We recommend disclosing contact information for the reseller of the consumer credit information, though you may want to confirm this with your regulator. Under the Fair Credit Reporting Act, you are required to disclose the contact information for the “consumer reporting agency” providing the credit score used by the bank and the name of the person that provided the credit score upon which that credit score was created.

“Consumer reporting agency” is defined as an entity engaging in the “assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties.” 15 USC 1681a(f). A company that merges and resells such information is included as a “consumer reporting agency”: “The term ‘reseller’ means a consumer reporting agency that assembles and merges information contained in the database of another consumer reporting agency or multiple consumer reporting agencies . . . .” 15 USC 1681a(u) (emphasis in bold added).