Thank you. One more question - Does the customer need to know that they did not meet our minimum credit score requirement? Does it need to be in the notice along with the specific denial reasons? Or just list the reasons?

For the AA notice, no, since your credit score requirement is not a specific denial reason and shouldn't be used as a reason for denial on your AA notice. As far as customer service, it might be nice to tell them, but I don't see a requirement to do so.

I can't recall a single application with a credit score below what is acceptable under policy, that the reason for denial isn't one of the below reasons:
Delinquency
Collections
Bankruptcy
Limited Credit Experience (might not include anything derogatory...it's just a very short report)
Poor performance with prior loans at my bank.

Thank You.

I'm not sure that it isn't required if it can be considered an "Automatic Denial Reason," which it often is.

8. Automatic denial. Some credit decision methods contain features that call for automatic denial because of one or more negative factors in the applicant's record (such as the applicant's previous bad credit history with that creditor, the applicant's declaration of bankruptcy, or the fact that the applicant is a minor). When a creditor denies the credit request because of an automatic-denial factor, the creditor must disclose that specific factor.

I agree that it isn't sufficient to say your credit score was too low (which, let's be honest, is really dumb when it's a combined FRCA ECOA AAN), but I do think it is required in some circumstances.

I don't think it's necessary to add this to your credit policy. You're denying based on score, and the AAN denial reasons are what the applicant needs to do to be creditworthy. In this scenario, that equates to the reasons the score is too low. Your auditors should be looking at the denial reasons in context of both your policy and the applicant's CBR.