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#1740691 - 09/13/12 06:20 PM Reg B and AAN requirements
Many Hats Offline
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Joined: May 2008
Posts: 915
Orlando, FL
Is is ok to have this on a commercial application? Or, if the gross annual revenue is below $1 mil - is the bank REQUIRED to send the AAN within 30 days?

"If your gross revenues was $1,000,000 or less in your previous fiscal year (excluding trade credit, a factoring agreement, or similar types of business credit), in this
Commercial Loan Application, and if your application for business credit is denied, you have the right to a written statement of the specific reasons for the denial. To
obtain the statement, please contact: Bank, ATTN: Loan Operations P.O. Box ###### within 60 days from the date you are notified of our decision. We will send you a written statement of reasons for the denial within 30 days of receiving your request for the statement. The notice that follows describes additional protections extended to you.
Last edited by Many Hats; 09/13/12 06:21 PM.
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#1740705 - 09/13/12 06:38 PM Re: Reg B and AAN requirements Many Hats
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
Having that on the application will not do you any good as the disclosure has to be in a form the customer can keep. They give you the application. If you deliver the notice appropriately, then you would be correct and no written AAN would be required.

1002.4(d) Form of disclosures. (1) General rule. A creditor that provides in writing any disclosures or information required by this part must provide the disclosures in a clear and conspicuous manner and, except for the disclosures required by 1002.5 and 1002.13, in a form the applicant may retain.
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#1740711 - 09/13/12 07:03 PM Re: Reg B and AAN requirements Many Hats
Many Hats Offline
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Joined: May 2008
Posts: 915
Orlando, FL
On a related matter....is the following correct (which is in the bank's policy)? I thought the decision must be provided within 30 days of receipt of a completed application - not within 30 days of the bank making a decision.

"Pursuant to Regulation B, the Bank must notify the applicant of the credit decision in writing within 30 days after the completed application is received or the decision has been reached."

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#1740714 - 09/13/12 07:04 PM Re: Reg B and AAN requirements Many Hats
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
Which ever comes first, i.e. an incomplete application.
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