I have a business loan request that was declined. The owner of the business was listed as a borrower along with the business on this loan request. Credit was pulled on the individual. Would I send an adverse action to business and individual? Must I provide the credit score information to the individual borrower as well?
Regulation B only requires that you send the notice to one of them (the primary applicant if they can be identified). A FCRA AAN would have to provided to the individual if their credit report contributed to the denial (including the score disclosure if that played a part).
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So, if the primary business is ABC Corp, we could send the decline notice to the business address, but since we pulled credit on the business owner we would need to send him the FCRA AAN as well.....could I just send the decline notice and FCRA AAN to the business owner since he was actually an applicant instead of sending one to business address and one to him?
IMO, anything with his personal credit score on it should not be addressed to the company. To keep it clean, send the Reg B AAN to the business and the FCRA AAN to the individual.
Great, thanks for your help. I have another question regarding the key factors affecting credit, when there are only 4 and they include the number of inquiries then we have to list 5 correct? Where will the 5th one come from? There are only 4 listed on the report.
You only list what you have for factors. If the report only shows 4, including the number of inquiries, then you only list four. But you are correct - if the number of inquiries shows, you must list it, even if its the fifth factor.