Does anyone have any documentation, other than the vague regulation that can support my assertion. We have a retail manager who believes that adverse actions do not need to include "all" (limit 4) priciple reasons for denial. Thus, if a loan is denied for bad credit, the adverse action need only state bad credit. However if the same loan had a high ltv, short employment history etc., his assertion is that it would not need these items. I disagree with him. I believe that an AA nees ALL principle reasons for two reasons.
Lets say someone comes in and you deny them for bad credit. But they had bad credit and high ltv. A month later they come in and explain (and prove) that their bad credit was fraud or a misunderstanding and it was cleared up, what would you do next. Deny them again and switch the reasons? Also I believe an AA is a tool that applicants can use to clean up their credit history sufficient to get approved for credit.