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#2258849 - 08/27/21 03:06 PM Denial Reasons
dollars & sense Offline
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Joined: Oct 2006
Posts: 344
I am reading our bank procedures regarding notice of action taken and it states that regulators like to see 4 reasons for denial listed, so to list 4 reasons. Sometimes there aren't 4, just 1 or 2. I realize 4 should probably be a maximum but does anyone else agree with the way our procedures are written?

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Lending Compliance
#2258851 - 08/27/21 03:12 PM Re: Denial Reasons dollars & sense
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Paragraph 9(b)(2).
1. Number of specific reasons. A creditor must disclose the principal reasons for denying an application or taking other adverse action. The regulation does not mandate that a specific number of reasons be disclosed, but disclosure of more than four reasons is not likely to be helpful to the applicant.

If you only have one reason however, you only have one reason.
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#2258891 - 08/27/21 08:22 PM Re: Denial Reasons dollars & sense
Oursisnottoreasonwhy Offline
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Oursisnottoreasonwhy
Joined: Nov 2004
Posts: 504
Central Illinois
You list the 4 items that affected the credit score and mark if the number of Credit Inquiies affected the score. But you only need one reason for a denial and no more than 4

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#2258896 - 08/27/21 10:28 PM Re: Denial Reasons dollars & sense
Rocky P Offline
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Joined: Jun 2003
Posts: 7,659
Florida
I have looked at it as the purpose of an AAN is to tell the customer what they need to fix to get the loan.
The agencies say that more than 4 reasons might not be helpful - I can easily understand that they could think of it as discouraging someone from reapplying.

My take is they need to know what to fix to get the loan, and although discussed by the examiners, after the explanation, they have never criticized the bank (or compliance officer).
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