Method to Recon FNBO - And Is this Legal?

[seattlecredit08]

As a background, I recently applied for FNBO Evergreen Credit Card after seeing that I was prequalified using FNBO prequalification tool (I was prequalified for $13,500). What I like most about the card is that it offers SP-based CLIs.

When I applied, my application went into Pending Status (10-14 days).

About 2 weeks later, I finally received a letter with a denial for the following reason (exact quote from the letter is below):

We regret tgat we are unable to approve your application at this time, for the following reasons:

IDENTIFYING INFORMATION DOES NOT VERIFY

Later in the letter, Experian was listed as the CRA that was used and my Experian score of 790.

However, clearly FNBO did not deny me based on my Experian report or its contents but based on some other information, e.g. perhaps a secondary report such as Innovis or ARS or Lexis Nexis.  I double checked that address, etc. matches 100% to the Experian report which they pulled.

I have since tried to have the decision be reconsidered which FNBO did only to receive the identical 2nd letter with the exact same denial language. I have also since spoken to a Supervisor (after requesting a callback) who was completely unhelpful and just kept repeating "This is our final decision."  I could not get any details on what other sources of information were used and when I told them that I can send them my Drivers' License / Utility Bill / Etc, they would not accept anything and would not provide where I can send this information, to get over the IDENTIFYING INFORMATION DOES NOT VERIFY  denial. 

My question --  Is it even legal for FNBO to issue a denial but not cite the source used in the denial (clearly it was something else other than Experian)?

I would understand if they denied me based on my Experian report but clearly this was not the case. In other words, is it legal for a Credit Card issuer to pull information from sources A, B and C and deny based on B but cite only A as the source of information in their denial letter? 

Separately, does anyone have any tips on how I can overcome this?  I am certain that if I reapply, I will get the exact same result, regardless of my FICO score or what is on my credit report.

Has anyone else ran into this issue with FNBO? In the past, whenever I ran into a similar situation (identify verification denial), I would simply provide my Driver's License / Proof of Address but FNBO is refusing to even take anything and is saying that there is nothing I can do to verify myself.

All pointers, prior experiences with FNBO or suggestions are welcome. Thank you very much in advance! 

[Jnbmom]

Unfortunately they can deny you for any reason they deem fit nothing "illegal" about that . At times we don't understand creditors logic or their reasons.Since you have tried to recon and spoke to a supervisor I don't think you have any other avenues but to

move on to another creditor to do business with .

Maybe others have suggestions , it appears something with your identity is not lining up and as you mentioned they may be using another agency to cross reference ?

[zerofire]

Do you remember the identity questions you answered as part of the application? Most likely somewhere you either missed them or flat out answered one wrong. That is the most likely issue that you suffered. As a result they are not going to consider this application. I believe my application with Santander had similar problems. The website was extra glitchy and I would not be surprised if my browsers filters completely removed the verification questions. On that app I did not fill any in.

[seattlecredit08]

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@Jnbmom wrote:

Unfortunately they can deny you for any reason they deem fit nothing "illegal" about that . At times we don't understand creditors logic or their reasons.Since you have tried to recon and spoke to a supervisor I don't think you have any other avenues but to

move on to another creditor to do business with .

Maybe others have suggestions , it appears something with your identity is not lining up and as you mentioned they may be using another agency to cross reference ?

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Thank you!  I guess my core question is--- If the creditor such as FNBO uses let's say two separate sources of information, e.g. Experian and Innovis and they deny you based Innovis while everything looks great on the Experian report, doesn't the credit than have a direct obligation legal obligation to mention that they used information from Innovis to reach their decision versus just include a template letter with Experian score which did not play a role in their decision?

From what I am reading, for example, CFPB has a clear regulation (CFPB 12 CFR Part 1002 (Regulation B), Section 1002.9 - Notifications) that states:

If credit is denied, the applicant must be given the specific reasons for the credit denial (or notice of the right to receive the reasons)

Question-- Wouldn't denying on let's say data from Innvois and omitting in the denial letter that the decision was based on Innovis data be in direct violation of this regulation?

By the way, there were no questions to verify, it was a simple 1 page application.

Thank you again!

[Anonymous]

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@Jnbmom wrote:

Unfortunately they can deny you for any reason they deem fit nothing "illegal" about that .

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I don't think it is quite that simple, they can indeed deny you for any non-prohibited reason, but once they make a claim based on a credit report, the FCRA requires them to supply the name of the reporting entity:

• You must be told if information in your file has been used against you. Anyone who
uses a credit report or another type of consumer report to deny your application for credit,
insurance, or employment – or to take another adverse action against you – must tell you,
and must give you the name, address, and phone number of the agency that provided the
information

But I think here the situation is different: it's not say "multiple late payments" in which case that would need to be backed up.   You "merely" haven't provided information that makes them sure of your identity, there isn't a place that has negative info.

[zerofire]

If a lender accesses multiple reporting providers they should be listing each one on the denial letter. As for the accuracy of the letter itself that depends on the lender and how much time the underwriter has to put it together. Some can be less than perfectly put together and be valid as the bad parts are just a grey area. It is well known that for a CC application some lenders put a lack of a mortgage or lack of millions in investments as denial reasons. Those obviously are not the real reason for the denial but are contributing factors in the decision when on the edge. The key part is that the main reasons make sense. You as applicant liking the reasons has nothing to do with it.

[Jnbmom]

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@Anonymous wrote:

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@Jnbmom wrote:

Unfortunately they can deny you for any reason they deem fit nothing "illegal" about that .

---

I don't think it is quite that simple, they can indeed deny you for any non-prohibited reason, but once they make a claim based on a credit report, the FCRA requires them to supply the name of the reporting entity:

• You must be told if information in your file has been used against you. Anyone who
uses a credit report or another type of consumer report to deny your application for credit,
insurance, or employment – or to take another adverse action against you – must tell you,
and must give you the name, address, and phone number of the agency that provided the
information

But I think here the situation is different: it's not say "multiple late payments" in which case that would need to be backed up.   You "merely" haven't provided information that makes them sure of your identity, there isn't a place that has negative info.

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Very true I guess my point was they can claim they can't validate one's identity and cited Experian as the source , not sure how you can fight it even though it makes no sense . That's kinda is what I meant they can shoot out whatever reason they want , but if they used another source they have to supply that information . 

I had issues from some lenders citing the could not verify my identity through TU and everything is accurate on my file .

[AndySoCal]

If you get your credit report from annualcreditreports.com as a part of the process you are asked 4  questions. Most of the time those questions are from Experian not always.  Did FNBO ask 4 questions regarding what is on or not on your credit report?

[coldfusion]

Attempting to fight this will be an uphill battle.

This could be a validation error for example because you answered a silly question wrong ("Which of these streets is closest to you?" is a personal favorite) or someone else's information is being incorrectly reported on your file like someone else's death certificate.

In the meantime get copies of your credit reports from the 3 major CRAs as well as Innovis/ARS/SageStream and a copy of your LexisNexis consumer report to check for errors and discrepancies.  If there are errors work to dispute them off, first starting with Lexis Nexis.

It's quite possible that you for example have conflicting information being reported on your Lexis Nexis file like having multiple different SSN recorded.

[Heatt99]

This happened to me about 5 months ago. I already had the Evergreen card for 6 months. Limit 15k auto increased to 18k.

Checked for pre-approval for Getaway card,, and saw an offer. Auto filled my info and got denied for unable to identify!!!!

When i got the denial letter, I noticed the address # was off by one digit. Called recon to explain, and still got denied for card.

Same with Well Fargo. Get mail offers often. Went on site, did auto fill, and no offers came back. Typed my info in manually, and was offered all cards.

So with my situation I know its auto fill mixed with cookies thats messing up my apps.