FTC has a Guide specific to landlords and credit reports here. It's old, but still applicable.
They even have a simple, downloadable guide here.
The verbiage on compliance is:
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Non-Compliance with the FCRA
Landlords who fail to provide required disclosure notices face legal consequences. The FCRA allows individuals to sue landlords for damages in federal court. A person who successfully sues is entitled to recover court costs and reasonable legal fees. The law also allows individuals to seek punitive damages for deliberate violations of the FCRA. In addition, the Federal Trade Commission (FTC), other federal agencies and the states may sue landlords for non-compliance and get civil penalties.
However, a landlord who inadvertently fails to provide a required notice in an isolated case has legal protections, so long as he or she can demonstrate "that at the time of the . . . violation he maintained reasonable procedures to assure compliance" with the FCRA.
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@Steve Babiak, it is pretty unlikely that the CFPB would target landlords, but if a sharp consumer were to file a complaint, they may pursue. Since the law does allow punitive damages and court costs, a snaky lawyer may even jump in their corner. If you utter the word "Credit" to a consumer, I'd take a couple minutes to stay compliant.
It's pretty simple to stay compliant. Just generate the letter from any of the online templates, make a copy and mail it out. Throw the copy in a file (or scan it and upload it to the cloud) along with a couple notes of why you declined and when you mailed the letter. This covers the whole - “that at the time of the . . . violation he maintained reasonable procedures to assure compliance” - part.
I'd personally use this template because it's well, formatted, complete and has easy to use check boxes.