Currently we provide the Reg B and Reg V notice to all applicants when a adverse action notice is required, unless the cusomer does not have a credit score, then the Reg B notice is all that is given. Is it okay to always give the Reg V notice?

Reg V is a risk-based pricing notice - meaning the applicant is approved but the rate was higher. Why do you give it when an AAN is required?

I'm sorry I should have been more clear. I mean the Reg V FCRA notice that is required along with the ECOA notice on the AAN.

Thank you for the clarification. For the record, the FCRA AAN requirements are not included in Regulation V. The law is the only place you'll find those requirements.

It is not always okay to give the FCRA notice. You only provide it when you have used information in the credit report to take adverse action. If you did not pull a credit report, you would not provide the FCRA AAN.

You would not condition providing the FCRA AAN on whether there was a credit score or not. You can use deliquency and other information on the credit report to take adverse action. The only part of the FCRA AAN that would be affected by not having a credit score is the new credit score section. If no credit score, you wouldn't fill out that part of the AAN, but you would still indicate that you used the credit report.