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#1790206 - 02/28/13 05:42 PM Business Adverse Action Notification
LAK Offline
Junior Member
Joined: Oct 2012
Posts: 43
Which direction to travel? Business application denied, whether over the million or under gross revenue, do you feel the following would meet the compliance requirments? Lender notifies the applicant orally of the decision and provides reasons at that time (doucment). The lender then does a follow up with a form letter; thanking for the oppourtnity etc, name and lender to contact with questions and then include the ECOA notice. Would this meet all requirements for both? These would be strictly business denials. Thanks

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#1790226 - 02/28/13 06:09 PM Re: Business Adverse Action Notification LAK
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
As long as the letter conforms to the requirements of 1002.9(a)(2)(ii) for those with revenues of $1MM or less and to 1002.9(3)(ii)(B) for those with revenues over $1MM you should be OK.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1790306 - 02/28/13 08:24 PM Re: Business Adverse Action Notification LAK
SUSANE1 Offline
Platinum Poster
Joined: Mar 2008
Posts: 808
the notice that is to conform to the requirements of 1002.9(a)(2)(ii) - (is on the application) - and I had inquired earlier if I am to give that notice in the form the applicant can retain, and was told yes, but when I read 1002.9 (3) (B) - I can not see "in writing" or "form applicant can retain" - I see only the disclosure must contain the information, etc. ???
Last edited by SUSANE1; 02/28/13 08:25 PM.
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#1790324 - 02/28/13 08:44 PM Re: Business Adverse Action Notification LAK
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
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 ยงยง1002.5 and 1002.13, in a form the applicant may retain.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1790332 - 02/28/13 09:03 PM Re: Business Adverse Action Notification LAK
SUSANE1 Offline
Platinum Poster
Joined: Mar 2008
Posts: 808
Thank you! That is what I love about BOL & Banker's Threads - this is absolutely the best site to get solid information and answers

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