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#2238367 - 06/19/20 04:28 PM Decline Reason - Credit Score Too Low
InFairness, CRCM Offline
Platinum Poster
InFairness, CRCM
Joined: Nov 2010
Posts: 919
USA
I'm having a small disagreement with a business unit. When they auto-decline credit card applications because the credit score is too low, the adverse action notices give the decline reason as "insufficient credit score." I know there is regulatory guidance on this beyond the official staff commentary on Reg B, but I am having brain fade and cannot remember where. Can someone please point me in the right direction?

Thanks!
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Opinions are strictly my own, and have nothing to do with my employer.

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Fair Lending
#2238372 - 06/19/20 04:37 PM Re: Decline Reason - Credit Score Too Low InFairness, CRCM
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
See 1002.9(b)(2) and its related OSI.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2238375 - 06/19/20 04:57 PM Re: Decline Reason - Credit Score Too Low InFairness, CRCM
InFairness, CRCM Offline
Platinum Poster
InFairness, CRCM
Joined: Nov 2010
Posts: 919
USA
Thanks, Dan.
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Opinions are strictly my own, and have nothing to do with my employer.

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