We just withdrew a loan per the borrower's request. In this instance we had already pulled his credit. We are withdrawing the loan. Credit was good. Do we have to include the credit scores on the adverse action?

A borrower withdrawing their loan application is not an adverse action by the lender. No AA notice required. Document on the loan application/credit report the date customer contacted you & that they withdrew their loan application.

We file these in our AA files to keep them for 25 mos. - should customer change their mind about the loan, within the timeframe of which we don't require a new credit report be obtained.

I know it's a bit late, but . . . Agree - JL, 2 comments (covered by Dorothy)

The customer is the only one who can "withdraw" the application for consideration (not the bank, and the customer can do it only before the lender makes a decision), and

Since the customer made the decision, the lender is not taking any adverse action (customer is instructing the bank), and no adverse action is needed. In fact, if one was sent, it would confuse things.