I need a little help with Reg B adverse action notice for business accounts. Business accounts less than a million we can give them a disclosure at time of application that contains the applicants right to request specific reasons for credit denial. If you have a phone application you can tell them orally. As an auditor how would you verify that the applicant has been given this verbally or written. Would you satisfy this requirement if your best practices state you give this at application? Just not sure how to audit this? Any suggestions?

It would have to be more than a "best practice". It would have to be a component of your written policies and procedures. But I find it hard to believe that you are going to get commercial lenders to actually read the ECOA notice to a telephone applicant.

I would agree with you on the telephone applicant. Sorry our bank calls our procedures "Best Practices".

If possible, staff interviews may also give you a good idea of what is actually happening. For example, how are adverse actions handled for phone applications? Are you looking to take advantage of the allowance for phone applications and if so, how does that look?