I'm reviewing a denial that gives a single reason for denial. After reviewing underwriting notes, there are 2 reasons for denial. A corrected denial has not and will not be sent.
To complete our LAR do we only include the reason from the Adverse Action Notice or do we include both reason in the underwriter's notes on the LAR?
This commentary sounds like we report the incorrect/incomplete denial reason from the AAN.
https://www.consumerfinance.gov/rules-policy/regulations/1003/Interp-4/#4-a-16-Interp-1
3. Reason for denial - adverse action model form or similar form. If a financial institution chooses to provide the applicant the reason or reasons it denied the application using the model form contained in appendix C to Regulation B (Form C-1, Sample Notice of Action Taken and Statement of Reasons) or a similar form, § 1003.4(a)(16) requires the financial institution to report the reason or reasons that were specified on the form by the financial institution, which includes reporting the “Other†reason or reasons that were specified on the form by the financial institution, if applicable. If a financial institution chooses to provide a disclosure of the applicant's right to a statement of specific reasons using the model form contained in appendix C to Regulation B (Form C-5, Sample Disclosure of Right to Request Specific Reasons for Credit Denial) or a similar form, or chooses to provide the denial reason or reasons orally under Regulation B, 12 CFR 1002.9(a)(2)(ii), the financial institution complies with § 1003.4(a)(16) by entering the principal reason or reasons it denied the application.