I'm also going to piggy back on this thread, since this was discussed above. If we have a consumer credit application that was denied due to insufficient collateral, outside of our trade area, or the term requested exceeds bank policy, and information in the credit report was not the reason for the decline (i.e. customer's credit score was above min cutoff and all other credit information met our standards), would we be in violation if we sent a combined FCRA/Reg. B adverse action notice to the customer, when only the Reg. B AAN was required?

If your form follows Model Form C-1 in appendix C of Regulation B, you will be in compliance. The combined notice includes a checkbox to indicate that the credit decision was based in whole or in part on the credit report. You simply skip checking that box, and don't provide the name and address and phone number of the credit reporting agency when it doesn't apply.

John is right but to be more direct: you should NOT mark the FCRA box when the credit report has no bearing on the reasons for denial. Overkill (over disclosing) is not okay in this case. You're wrongly alerting the customer that there is something wrong with their credit report, when there isn't.