We have a lender that recently left her position at the bank. After doing so, we found two denied motor vehicle applications in her desk. Adverse actions were not sent within 30 days. They are dated back in May of this year. Any advice on what we should do in this situation? We feel like if the adverse actions are sent now, the applicants will be very confused because it happened so long ago.

Even if they are late, we send them. There is a lot of information on these notices that consumers are required to receive. I'd rather have an examiner criticize me for a late AAN than for not providing one at all.

As far as customer confusion....it would be OK to cover these with a letter of explanation....such as "a review of your application dated _______ indicates that the attached _________ was not mailed to you. We apologize for any inconvenience."

That's pretty generic. We've been known to let our marketing team "spice up" this type of notification since they think with a different part of the brain than we do.

We would also add a cover letter explaining why they were just now receiving the notice, since it was so far past the application date. There is a possibility that if you don't send this now that your examiner would force you to anyway, and then you would be even further out from the app...