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#1719685 - 07/12/12 10:27 PM AAN to co-signer
pat robbins Offline
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Joined: Jun 2007
Posts: 87
Oklahoma
From reading previous threads we are not required to send a AAN to a co-signer. Is it a problem if we did send one? We sent separate AANs; one to the applicant and one to the co-signer. We pulled a credit report on the co-signer and did disclose his credit score on his AAN but gave no info on the applicant. Is this OK?

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#1719708 - 07/13/12 11:45 AM Re: AAN to co-signer pat robbins
KPOC Offline
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You are correct, cosigners do not receive AANs.

"Under section 701(d)(6) of the ECOA and 202.2(c) of Regulation B, only an applicant can experience adverse action. Further, a guarantor or co-signer is not deemed an applicant under 202.2(e). Sections 603(k)(1)(A) and 603(k)(1)(B)(2) of the FCRA provide that adverse action has the same meaning for purposes of the FCRA as is provided in the ECOA and Regulation B in the context of a credit application. Therefore, a guarantor or co-signer would not receive an adverse action notice under the ECOA or the FCRA." [Regulation B; Docket No. R-1408]

Since you sent each consumer an AAN with their own credit score only, I don't see this as a problem.

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#1719840 - 07/13/12 03:14 PM Re: AAN to co-signer pat robbins
Andy_Z Offline
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I agree with KPOC. You haven't harmed the bank with the notice, but it wasn't required.
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#1719870 - 07/13/12 03:49 PM Re: AAN to co-signer pat robbins
pat robbins Offline
Member
Joined: Jun 2007
Posts: 87
Oklahoma
Thanks.

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