Adverse Action Notices: Giving the Reasons for Denial

Under Regulation B, when you take adverse action in connection with an application for a credit product or service, you must provide an adverse action notice. There are several things that are required to be included. For example, a statement of the action taken, the creditor’s name and address, the ECOA statement, the name and address of the bank’s primary regulator, etc. You also have to tell the applicant the reasons for the adverse action. That’s usually not that difficult to do, but did you know there are actually a couple of different ways to do this?

David explains more in the video.


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Video Highlights:

  • Regulation B specifies the information required to be disclosed on an adverse action notice.
  • The reasons that led to the adverse action notice should be specific.
  • Regulation B does allow an option to provide a “no reasons” adverse action notice.

Published
2023/04/21
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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