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#1261122 - 10/02/09 06:49 PM Denials and the joint form
Curious Banker Offline
100 Club
Joined: May 2004
Posts: 184
Midwest
I am new to FCRA and have read several threads on this but am still having troubles. Our system prints a single combined adverse action form (ECOA and FCRA) regardless of the number of applicants. All applicants’ names appear at the top of the form. Bob & Jane apply for a loan. If we deny due to Bob’s credit only and send a combined form to both Bob and Jane, do we need to indicate on the form which of the two has the bad credit? And, as Jane does not need the FCRA disclosure, is it an issue to provide one to her as we are using the joint form?

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#1261180 - 10/02/09 08:05 PM Re: Denials and the joint form Curious Banker
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Each should get their own FCRA notice. Over disclosure is not acceptable.

Ideally, you would prepare one AAN that has Bob's name on it with his specific info and with Jane's name with her info.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#1261195 - 10/02/09 08:18 PM Re: Denials and the joint form David Dickinson
Curious Banker Offline
100 Club
Joined: May 2004
Posts: 184
Midwest
Agreed but still have an issue with only one form printing and, loans would like all reasons for denial to be on the system. So, Bob and Jane both are denied for credit but Bob's is due to excessive obligations and Jane's is that she pays late. One form prints with both names at the top and both reasons. I really do not want to suggest a manual process and have a hand-completed form for each sent out and then not use the system generated form. Is there any work around based on the info I provided or will I need to suggest the manual process?

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#1261222 - 10/02/09 08:42 PM Re: Denials and the joint form Curious Banker
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I'm not aware of any work around that isn't manual if you system can't produce an AAN for each. I'd contact your vendor and ask them what you're supposed to do in these situations. The SHOULD be familiar with the regulatory requirements.
_________________________
David Dickinson
http://www.bankerscompliance.com

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