Applicant applied for an auto loan and it was determined that a co-signer would be needed after credit was pulled. The following day the applicant brought in a co-signer. The co-signer did not qualify as well due to poor credit. Do we need to send the applicant and co-signer seperate adverse actions? What else do we need to do? I beleive that we need to send the applicant and co-signer seperate adverse actions because credit was pulled.

I agree, seperate adverse action notices.

Reg B AAN - only needs to be sent to the primary applicant.

FCRA AAN - needs to be sent to all consumers whose credit report was used in whole or in part in the adverse decision.