Our Credit department recently denied a request (applied for PRA) becasuse the applicant is a minor and the Bank wouldn't have a legal binding contract.

We need help with the verbiage for the Adverse Action Notice without violating the Regulation B.

Only one reason needed:

Applicant is not of legal age to contract.

Randy is correct. When documenting reasons for denial, I've always offered this advice: Think about the true reason you are denying the application.

On the surface, you might say you're denying it because of the age of the applicant, but that's not really the reason. As Randy points out, you're denying it because you would not have a legally enforceable contract. It's OK to turn someone down for that reason, and it's not always related to age, so there's no disparate impact theory to worry about either.