Adverse Action Letters to Multiple Parties
Answer by Andy Zavoina, BOL Guru BIO AND CONTACT INFO
Question: When we send an adverse action letter on a consumer loan, do we need to send the letters to all parties separately or, if they have the same address, can they be included in one envelope?
Answer: §202.9 Notifications.(f) Multiple applicants. When an application involves more than one applicant, notification need only be given to one of them but must be given to the primary applicant where one is readily apparent.
That said, if your AAN contains the FCRA notice and that notice applies to the other applicant, it must be made.
There was once concerns of confidentiality between telling one applicant that the other had derogatory credit, as an example. The new version of Reg. B says that concern is dismissed when people co-apply.
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