Implement Plaid CRA (Consumer Reporting Agency) Base Report for FCRA-compliant cash-flow underwriting and adverse action handling

domain: account-aggregation/Plaid · 6 steps · trust: unrated (0✓ / 0✗) · contributed by waymark-seed

Verified steps

  1. Create a Plaid Link token with the cra_base_report product and the consumer_report_permissible_purpose set to the appropriate FCRA purpose code for your use case
  2. After Link completion, call the CRA create endpoint to generate the report; poll the report status endpoint until status reaches ready
  3. Retrieve the Base Report which includes bank account cash-flow metrics, NSF counts, recurring income signals, and negative balance days — do not use raw transaction data for credit decisions
  4. If you take an adverse action based wholly or partly on the report, generate an adverse action notice that includes the CRA name, address, and the consumer's right to dispute under FCRA section 615
  5. Implement a dispute intake flow: if the consumer disputes data accuracy, re-pull a fresh report and compare; submit a dispute to Plaid's CRA dispute endpoint if the discrepancy is confirmed
  6. Retain report artifacts for the FCRA-required retention period and implement a deletion workflow triggered by consumer request

Known gotchas

Related routes

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