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#2015591 - 05/21/15 08:52 PM Adverse Action Notices
NSF, CRCM Offline
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NSF, CRCM
Joined: Apr 2013
Posts: 410
VA
We have just switched to a new document provider and now have the option to issue AANs in alignment with 1002.9(a)(2)(ii).

This has lead to my question. The customer writes the bank and requests their reasons for denial in writing. Does the letter we send to the customer with their specific reasons for denial have any formatting requirement? Does it have to have other information other then the reasons for denial? (We would include their name, address, etc. of course.)

I don't see where the regulation specifies so I just wanted to make sure I am not missing something.
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It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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Lending Compliance
#2015593 - 05/21/15 08:57 PM Re: Adverse Action Notices NSF, CRCM
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
There are no stated requirements. I would refer back to the date of the adverse action notice so that the documents are tied together.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#2015665 - 05/22/15 01:40 PM Re: Adverse Action Notices NSF, CRCM
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
NSFW: What you'll find is that VERY few applicants will require you send them the reasons in writing. We have several banks that do this approach and all tell me that it is rare to have to follow up with the reasons.

Most of the time, the loan officer calls them and says "I'm sorry. We can't make this loan because ____". Then the bank sends the "no reason" AAN. That's the end of it, in reality.

I don't know why more banks don't do it this way.
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David Dickinson
http://www.bankerscompliance.com

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