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Covered Topics
- The adverse action notice requirements of both the Equal Credit Opportunity Act (Regulation B) and the Fair Credit Reporting Act;
- How to complete the model adverse action form;
- The rules for providing notices to multiple borrowers;
- The rules for determining who provides the notice in situations with multiple creditors or a broker and an investor;
- Proper handling of counteroffers, and withdrawn and incomplete applications;
- Timing rules for adverse action notices;
- How to select the correct reasons for denial;
- Rules for commercial loans;
- The differences between applications, completed applications and inquiries, prequalifications and preapprovals;
- When an adverse action notice is needed for a deposit account;
- Listing credit scores for adverse action versus the HMDA LAR;
- Who is listed as the credit bureau where the credit report is obtained from an aggregator who includes three credit scores from three different companies; and
- Common errors in completing adverse action notices