We are reviewing adverse action notices. We have come across one from early 2015 where we feel the incorrect reason was marked by underwriter. Is it acceptable to send out a new adverse action at this point to show the correct reason?

I think that would be like putting salt on a wound. I would put together a training package instead.

Worked at a bank once that HAD to send out new ones at the request of dudes with federal IDs. Just a handful of them, but our reasons were wrong. We devised a nice letter that said we were reviewing past loan applications and "realized" that the info we provided to them was not as useful as it could have been. Therefore, enclosed please find a better description of why you were denied credit from us (some 18 months ago....) We regret that we didn't provide the best information in a more timely fashion, etc., etc.

I'm sure it was received like Rocky said....like salt, but we did the best we could.

And, yes, first some new controls on the letter production and then some training and auditing came next.

The CFPB is really focused on was the "customer squared up". (quote from a CFPB panel.) I think that all of the regulators would question why you did not send the revised AAN. You will not avoid a violation cite if these AANs are looked at during a compliance exam, but the regulators will question why corrective action (toward the customer) was not taken. And, they will make you send a revised AAN anyway. If it is truly just a few, you can hope that it is not found. But, why not send the letter to the customer? I have used similar language as suggested above. This can then be sold as a success for the CMS.--monitoring occurred, problems were detected, employees were trained, AND the customer was "squared up."

I've been on both ends - once where the financial advisors were withdrawing applications rather than declining a client with 7-8 figure investment accounts, and the regulators made the bank put the credit score/date and appraisal/date/value on the 1003 into a spreadsheet and compared the information with the "withdrawal date". They had to go back 3 years (25 months plus 11 months it took to finish the exam) and send AAN's. Something that they did not want initially to do to offend a wealthy client.

My comment above was there was a single exception over a year and a half ago. I have never had a regulator go ballistic over a single exception, and with the exception of a 100% flood error - a senior lender waiving flood insurance (1 of 1), never have seen a single exception come up in a report. Of course, if they get the workpapers with the exception, they are going to look for the correction

I had an examiner find two or three AAN's with reasons that were either a little questionable or not properly documented. He required me to improve training, but didn't make me go back and redisclose. FDIC, 2015.