Two individuals apply for a loan in the name of a business and the loan is denied because the income of the two individuals is insufficient to cover the loan amount. Credit reports were used in determining their debt to income ratio.
Since the loan was denied based on the individual's income would you send adverse action letters to the individuals?
If the lender sent a letter to the business should he show that the decision was based on information in a CRA report?
I wouldn't think that we would do that since the information in the consumer report was for the individual and not the business.
My questions are:
1. Would we send letters to the consumers?
2. Should we reference the CRA in the letter to the business?

Commercial Application with Guarantor(s) is what it appears you have. If that is what you have, then you give the ECOA disclosure and you mark "Disclosure Inapplicable" on the FCRA portion, send it to the President of the business and you are done.

The reason in your "reasons" box "credit history of guarantor".

Truly, in re-reading your post, it doesn't appear you are actually denying on anything "in" the credit report..debts should have already been disclosed. It appears you are denying for "insufficient income", I would probably use that as the reason, rather than what I put above...depending on what you really have.