Remember that the AAN is two-fold (for now). Both ECOA and FCRA. Under ECOA, adverse action is explained in the commentary as "If the applicant applied in accordance with the creditor's procedures, a refusal to refinance or extend the term of a business or other loan is adverse action." If you take "adverse action" on the application, you are required to send the notice under Regulation B, section 202.9. If the adverse action is based on information contained in a report obtained from a third party credit reporting agency (credit report/score), then the additional notice language under FCRA is required.
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CRCM