I am curious to see how many of you are using the option to disclose to small business at the time of application of their right to receive a written statement of the denial reasons if their request is turned down (with the ECOA notice) vs. doing this at the time of denial as you do on consumers. Our commercial lenders are wanting me to change to the upfront option so they don't have to do decline letters for business customers, but I am not comfortable with that given how many times I have seen that they don't use our business application package and instead take financials/PFS as the application.

Business Adverse Action Options
At application
Once the application is declined

Thanks for your input!

Thanks for a good polling question. The results are really not surprising.

They weren't all that surprising to me either, but I needed to see if I wasn't being flexible enough.

Our CLO wanted, also, to print it on the business application and be done with it. As you observe, many business loans are done without an official application. And even when there is an applicaiton completed and signed by the customer, ECOA requires that the notice be given in a form that the customer can keep. How many times do we give a copy of the application back to the customere?

I have never supported the option to disclose the right to an explanation of the denial at the time of application. The point was made that you could do it once and be done with it. Quite frankly, I don't think reminding the customer when they want to see the reasons for denial that they were told up-front how to request the same would do anything for customer relations or your bank's reputation. I think that option flys in the face of the spirit of ECOA. When you deny someone access to credit - tell them!