Thank you for everyone that attended the Adverse Action Notice webinar! There are several pieces of information relating to the webinar that we would like to post and make available to you. To make sure all of the related material stays in one place, we will continue to update this post when additional information becomes available.
-Adverse Action Notice – Reg B Webinar, July 21, 2011.
Adverse Action Notice – Reg B PDF
-Many of you were looking for the credit bureau risk scoring reasons. Wendy Gillies was nice enough to forward Audit Link a copy of her list. See the link below.
*Updated July 22, 2011*
We made the following changes to the Adverse Action Notice based on your feedback from the webinar:
- The verbiage “We are unable to offer credit for the reason shown under below…”. Removed “under”.
- Added a line under the CRA for the credit union to enter a website.
- Increased the field size for the applicant name.
- Added an additional line for the member address.
- Added a line for the CU website.
*Updated 8/26/11*
The Adverse Action OnDemand video
One Comment
Per the recent amendement to Regulation B, page 41596 of the Federal Register (http://www.gpo.gov/fdsys/pkg/FR-2011-07-15/pdf/2011-17585.pdf):
“Several industry commenters asked who should receive an adverse action notice when a credit application involves multiple applicants. These commenters stated that applicants should not receive each other’s credit scores. They also recommended adding language to the model forms to indicate that for co-applicants, the adverse action decision may be based on either or both of the applicants’ credit information. They explained that such language would decrease consumer confusion, since an applicant with an excellent credit profile who receives an adverse action notice may not realize that the adverse action decision may have been made because of the co-applicant’s credit profile.
…..The Board believes that providing this additional language on the model forms would complicate the disclosures without providing a substantial benefit to consumers. An applicant with strong credit who receives an adverse action notice will likely understand that the adverse action decision was based on the co- applicant’s credit information or will contact the creditor to inquire.”
We have chosen to use “Other” then state: “Loan doesn’t comply with credit union lending standards”.
What are others doing in this situation?