I'm fairly certain we'll have to send out decline letters to all PPP applicants that had pending applications when the PPP funds were exhausted, but I'm really hoping to find a way not to have to send out hundreds of declines. Is there any way around having to send these? We've referred everybody to a local CDFI that is still able to process applications.

Since you no longer can make the loan legally - why would an adverse action notice be needed. But I am sure you plan to communicate the status in some manner - correct?

(2) The term does not include:

(iv) A refusal to extend credit because applicable law prohibits the creditor from extending the credit requested;

Thanks Randy. I've never had to use that exception, but I'm glad it's there.