THe sceniro: We have a husband and wife applying for a loan. The wife's credit score causes us not to make the loan, the husband's credit is good but we won't do the loan because of the wife's credit.....We send separate AAN, the wife's includes her score and reasons why we can't do the loan,....the husband's has...."because your wife's credit wasn't good enough?"
I know I'm simplifing this, but what are other people putting on the AAN for the husband?

On his I would just say that the wife does not qualify for credit.

Also, I would refer to her as "co-applicant", not "your wife".

Saying that the co-applicant doesn't qualify does not meet the specificity requirements of Regulation B. It would be like saying "you don't meet our underwriting requirements". From a Regulation B perspective, there is only one credit application and the AAN has to tell them both why, either in one or two AANs. While there is some concern in sharing credit scores, the commentary to the 2003 amendments clarified, there is no privacy concerns regarding sharing the reasons for denial.

We complete the AA for both of them with the reasons specified for the denial, and each receives their own credit score. If the husband calls to question, we would inform him the co-applicant did not qualify, but would not disclose score or any other information from the credit report. He can discuss that with the co-applicant

So "Alwayscomliant", you are saying you give an AAN for each person with their own score on it and both have the same denial reasons? OR one AAN with the same denial reasons and both their scores listed on one AAN?

rlcarey, would it be sufficient to send a separate AAN's with the husband's saying, "the joint applicant failed to achieve a qualifying score on the creditor's credit scoring system."

I'm not Randy but the answer is absolutely not. You have to give the reasons why they didn't meet the qualifying score.

From the Reg B 2003 revisions that became mandatory in 2004 that Randy keeps referring to:

9(b) Form of ECOA notice and statement of specific reasons
9(b)(2) Statement of specific reasons

Section 202.9(b)(2), adopted as proposed, clarifies that whether a creditor’s denial of credit is based on the creditworthiness of the applicant, a joint applicant, or guarantor, the reasons for adverse action must be specific. For example, a general statement that “the guarantor did not meet the creditor’s standards of creditworthiness” is insufficient.

The legislative history of the requirement to provide specific reasons for adverse action indicates that the purposes of the disclosure are to help achieve the antidiscrimination goals of the ECOA and to educate and inform consumers. These dual purposes are served by the clarification in § 202.9(b)(2). For example, the disclosure may discourage a creditor from discriminating based on a co-applicant’s or guarantor’s race, sex, age, or other prohibited basis. Also, the disclosure may help educate and inform applicants, co-applicants, or guarantors as to reasons for denial that are not apparent from looking at their credit report.

Many commenters were concerned about the co-applicant’s or guarantor’s privacy when the reasons for adverse action pertaining to creditworthiness are given to the primary applicant. When a person agrees to be a co-applicant, guarantor, or similar party, however, there is (or should be) a general understanding that information will be shared. Accordingly, the rule has been adopted as proposed.