“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?

The system currently displays a pop up warning indicating that the member has had previous transactions that day. The transactions could be anything from a check clearing, ACH posting, a transfer of funds etc… Many times the tellers tend to ignore the warning because they often just see that a direct deposit came in or a check cleared the account and the information is not really pertinent.

If we could isolate this warning to only trigger when transactions are performed in a branch at the teller window the front line staff would know that the comment was important. If they had the option to click on the warning to view the branch transactions within a configurable amount of time (3 days….one week) by time of day, teller ID and branch and better yet if the transaction was a cashed check to view the actual check, we could in many cases avoid these losses.

Linking transactions by SSN across multiple accounts would save time and systematically identify transaction layering (currently we have to review multiple reports and hope that we don’t overlook something). Linking transactions would give a true snapshot of the member and help greatly in identifying suspicious behavior.