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#1929329 - 06/04/14 03:47 PM Adverse Action Notice
dac Offline
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Joined: Sep 2009
Posts: 234
Which adverse action taken should be used for past due taxes and collections accounts?

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Fair Lending
#1929341 - 06/04/14 04:04 PM Re: Adverse Action Notice dac
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,911
Galveston, TX
Which adverse action taken should be used

What do you mean? Which form? How would you word it?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1929345 - 06/04/14 04:10 PM Re: Adverse Action Notice rlcarey
dac Offline
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Joined: Sep 2009
Posts: 234
The application was declined. Should the principal reason(s) for adverse action taken be collection action?

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#1929350 - 06/04/14 04:16 PM Re: Adverse Action Notice dac
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,911
Galveston, TX
How would we know what the principal reason(s) for adverse action taken might be on any specific loan you might be referencing? Only the person that did the underwriting can make that determination based on your specific underwriting criteria.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1929353 - 06/04/14 04:19 PM Re: Adverse Action Notice dac
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,911
Galveston, TX
If you are talking about which box to check on a standardized AAN form, refer to Regulation B:

The sample forms are illustrative and may not be appropriate for all creditors. They were designed to include some of the factors that creditors most commonly consider. If a creditor chooses to use the checklist of reasons provided in one of the sample forms in this Appendix and if reasons commonly used by the creditor are not provided on the form, the creditor should modify the checklist by substituting or adding other reasons.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1932942 - 06/16/14 07:09 PM Re: Adverse Action Notice dac
bankeraggie Offline
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bankeraggie
Joined: Apr 2014
Posts: 6
Our AAN allows us to select standard reasons for denial but also allows us to write in our own. Our officers fill in their AANs and I review it before mail out. In this case I would ensure the officer selected the "Collection action or judgment" along writing in "past due taxes." Also, I would make sure they included delinquencies if there were any on the credit report.
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The above is my opinion and nothing more

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