Our bank uses LaserPro and we have run into an issue with our joint AAN. LaserPro generates two disclosures one with the borrower's name and credit score, the other with the co-borrower's name and credit score, but on both forms it combines all of the denial reasons entered for both borrowers. So, if John and Jane get denied, John's bankruptcy and Jane's delinquent accounts are listed on both AAN without being separated by borrower. This may seem confusing and misleading for the borrower that might think there was inaccurate info on their own CBR's.

Any thoughts?

Reg B requires that the specific reasons for the AA be given. If the co-applicant's bankruptcy is a reason for the AA then that fact must be disclosed to the applicant. It appears LaserPro is doing what it is suppose to. However, I am not a LaserPro user.

Thank you for your response. I do agree that both of their reasons for denial do need to be listed, but my concern is that there is no differentiation as to who had the bankruptcy. Both disclosures say, "Reasons for denial: bankruptcy, delinquent accounts." LaserPro does not note who had the bankruptcy and who had the dilinquency.

Do you think that it is an issue?

We do not consider this an issue. For a number of reasons, we make sure that the Reg B reasons for denial are the same on both AANs, regardless of whether one reason only applies to one of the applicants. If one co-applicant did not have a bankruptcy, he/she will likely know that the bankruptcy applies to the other co-applicant. Not always, so there may be some confusion at times, but we don't feel that it is an issue that can't be easily resolved by answering any questions the applicants may have.

Same for the key factors? Just list all the same on both - the only difference being the scores on either notice?
Is that correct?

Rizz I would have to say that would be incorrect. The key factors affecting the individual scores most definitely could be different and you would need to list those affecting the specific score being disclosed.

I agree with Dan.

So - just to clarify - if joint applicants - one has bankruptcy and the other has good credit - we deny the loan request for bankrutcy - the 1st Exception Notice lists the principal reasons for denial, the credit score, the date the CRA was pulled, range of scores and the key factors. The joint applicant with perfect credit gets an Exception Notice listing the principal reasons for denial but it DOES not include the credit score, that date the CRA was pulled, etc.

And is the same for denying a credit product. Husband and wife want to open a joing DDA acc't. Wife has horrible credit - same as above?
.....Can we do a Notice of Adverse Action to the HUSBAND indicating we are unable to approve his request in its entirety but we can approve the DDA account in his name only - and then send the Notice of Adverse Action to the WIFE indicating we are unable to approve her requst - give her her credit score, etc?

With regard to your first question, there are some differing opinions on whether the co-applicant with great credit would get the FCRA section of the adverse action notice - see discussion here: http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1583016

Depending on where you land on whether to give the co-applicant the credit score notice, you would apply the same process (in my opinion) on the deposit side as well. Our deposit AANs only include the FCRA information, so we wouldn't be memorializing any kind of language in the AAN, as you have suggested, saying that the account could be opened for the husband only. It would just say the account could not be opened based on information in a consumer report.

Confused -so I am piling on. Borrower has no credit score- co-borrower has ok credit.

Borrower gets AAN with reasons, FCRA box checked, but no key factors, etc. because there was no score used.

Co-borrower gets AAN with reasons (optional), FCRA box checked, but no key factors, etc. because their score did not play into the lender's decision.

Is that correct?

It's debatable. I think many would agree that your statement is correct. If you issue combined Reg B/FCRA AANs, I think most would say to fill out the Reg B reasons for denial on the co-applicant's AAN with the same information as was shown on the primary applicant's AAN.

On the FCRA side, I've heard a lot of the gurus say that the FCRA notice only goes to a person if that specific person's credit was used in making the decision (so if the primary applicant's credit was the reason for the adverse action but the co-applicants credit is good, only the primary applicant gets the FCRA AAN). In the other thread I referred to above, I make the argument that it could be construed as both needing the FCRA AAN because an indidividual credit report was used. You'll have to read the thread for detail. But you can decide where you want your bank to land on that. IMO, either would be acceptable, unless your examiner lands somewhere else.

I attended the Lending Triage Conference today, and they commented that perhaps the CFPB will do some rulemaking here that could clarify the FCRA issues.

Thanks EmilyAnn _ I listened to it to and agree it is a grey area. I dedicided to err on the ultra conservative side. We pulled the person with the good credit's report and I don't want an examiner saying we should have checked the box just because the credit report is in the file. Besides, the staff is having a hard enough time with all these changes, if I throw another glitch into the AAN stuff - we might have a mass exodus!

Just had this situation come up today and read EmilyAnn's discussion above. That really helped me make my decision. Thanks for the great analysis.

I'm glad the analysis was helpful. Here is another recent thread that IMO lends even more support to the argument that both applicants should get the FCRA AAN, even if only one had poor credit leading to the adverse action: http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1652257&gonew=1#UNREAD