I just wanted to confirm/ask the following:

1. A H-4 form is not required on consumer loans in which we do not do risk based pricing?


2. "A Summary of Your Rights Under the Fair Credit Reporting Act" is not required if we send out a combined FCRA/ECOA adverse action? Would we need to send this out if the applicant is approved?

As I said before we do not do risk based pricing. Our lending software, has an option to print a "Consumer Copy" which include their credit report, "A Summary of Your Rights Under the Fair Credit Reporting Act", and the H-4 form for a denial. It seems like overkill, if we are also sending a combined AAN.