Under Regulation B, when you deny an application for credit, you owe the applicant an adverse action notice. There are specific requirements as to the timing of the adverse action notice as well as what information it must contain. One of these is providing the reasons for denial. While there is no list of preset reasons you are required to choose from, Regulation B does give some examples in the Sample Notification Forms found in Appendix C. Some examples, include “Length of Employment”, “Collection Action or Judgment”, “Value or Type of Collateral Not Sufficient”, etc. Whatever reasons you do give; however, must be specific. Giving reasons such as “poor credit” or “does not meet loan policy” aren’t specific and really don’t help the applicant in understanding why they were denied. Where we see non-specific reasons pop up the most is when loan officers try to get creative and/or use the “other” box or line on the adverse action notice form.
Jerod explains more in the video.
Published
2024/04/22
