The short version
What you're responsible for.
When you request a tenant screening report through Furnished Unfurnished, the report itself is generated and hosted by our screening partner, TransUnion SmartMove — a consumer reporting agency (CRA) under the Fair Credit Reporting Act (FCRA). Furnished Unfurnished never sees or stores the report's content, and we never score, rank, or recommend an applicant based on it. The decision to approve, decline, or condition an application is yours, and so is the legal obligation that comes with it.
Under FCRA §615(a) (15 U.S.C. § 1681m), if you take an “adverse action” against an applicant or tenant based in whole or in part on a consumer report, you must give them an adverse-action notice. This guide summarizes that obligation. It is general information, not legal advice — see the disclaimer at the end of this page.
The obligation, by the numbers
- Required elements in every landlord adverse-action notice under FCRA §615(a).
- 4
- Window for an applicant to request a free copy of their report from the CRA after your notice.
- 60 days
- Report content Furnished Unfurnished stores. Reports live in TransUnion SmartMove’s hosted portal.
- 0
Broader than a denial
What counts as adverse action.
“Adverse action” in a rental context is any unfavorable housing decision based even partly on a consumer report — and it covers a lot more than an outright rejection.
- 01
Denying the application
The clearest case — but far from the only one.
- 02
Requiring a co-signer or guarantor
Asking someone to co-sign because of a report finding is adverse action, even if you ultimately approve the applicant.
- 03
Requiring a larger security deposit
A deposit that "wouldn’t be necessary for another applicant" — the FTC’s own phrasing — counts, even without an outright denial.
- 04
Charging higher rent
Pricing one applicant above another because of report content is adverse action, not a pricing decision.
“If you think an action taken as a result of a background check might be an adverse action, it's safest to assume that it is.”
Upstream of the notice
Before you run a report.
The adverse-action notice isn't the only FCRA obligation — it's the last step in a chain that starts before you ever request a report. A screening request through Furnished Unfurnished invites the applicant to complete their own screening directly with TransUnion SmartMove, where they authorize the report as part of that process. You can only use the report for the purpose you requested it for — evaluating that applicant's rental application — and the obligation to keep it to that purpose, and to that applicant, is yours to uphold.
The core obligation
What the adverse-action notice must say.
If you take an adverse action based even partly on the screening report, FCRA §615(a) requires a notice with four specific elements.
- 01
The reporting agency’s name, address, and phone number
Include the CRA that furnished the report — TransUnion SmartMove for reports requested through Furnished Unfurnished — and a toll-free number if it operates nationwide.
- 02
A statement that the CRA didn’t make the decision
The notice must say the reporting agency did not make the adverse decision and cannot explain why you made it. That responsibility is yours alone.
- 03
The right to a free report within 60 days
The applicant can request a free copy of their file from the CRA if they ask within 60 days of your notice.
- 04
The right to dispute the report’s accuracy
The applicant can dispute the accuracy or completeness of anything the CRA reported, directly with the CRA.
An additional layer
If you relied on a credit score.
If a credit score was part of what led to the adverse action, you have obligations on top of the standard notice. Your written or electronic notice must also include the credit score itself, a description of the score (its source, the date it was created, and the range of possible scores under that model), and the key factors that adversely affected the score — listed in order of how much each one mattered.
Platform neutrality
Where Furnished Unfurnished fits in.
Furnished Unfurnished is not a consumer reporting agency. We facilitate the request for a screening report through our partner, TransUnion SmartMove, and we surface a status badge in your leads inbox once the report is ready — but we do not generate, store, score, or interpret the report, and we do not make or influence your rental decision. The report itself lives in TransUnion SmartMove's hosted portal; you (and, if you share it, the applicant) view it there.
That means the adverse-action notice obligation described on this page is entirely yours to meet, on your own timeline, in whatever form (written, electronic, or oral) you choose consistent with the FCRA.
Frequently asked
Common landlord questions.
- Does Furnished Unfurnished decide who gets approved?
- No. We never score, rank, or recommend based on a screening result, and we don’t see or store the report content — it lives in TransUnion SmartMove’s hosted portal. Every approval, denial, and any required adverse-action notice is a decision you make as the landlord.
- I only used part of the report to make my decision. Do I still need to send a notice?
- Yes. FCRA §615(a) applies whenever a consumer report is a factor "in whole or in part" in an adverse decision. If the report played any role, the notice obligation applies — even if other factors (income, references, timing) mattered more.
- Can I give the notice orally instead of in writing?
- The FCRA allows written, electronic, or oral notice. In practice, written notice (email counts) is strongly recommended: it gives you a documented record of compliance and gives the applicant something to act on to request their report or dispute an error.
- What if I used a credit score as part of the decision?
- If a credit score played a role, you have additional disclosure obligations beyond the standard adverse-action notice — you must also give the score itself, its source and date, the range it falls in, and the key factors that affected it, in order of importance. See the "If you relied on a credit score" section above.
- Is this page legal advice?
- No. This is a plain-language summary for general information only, not legal advice, and it is not exhaustive — state and local landlord-tenant law can add requirements on top of the federal FCRA baseline. Confirm your specific obligations with your own attorney, and see TransUnion SmartMove’s own adverse-action resources for a ready-to-use notice template.
Read the source
Where this guide comes from.
This page is a plain-language summary, not a substitute for the primary sources or your own counsel. For the full requirements and the latest federal guidance, see: