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#80516 - 05/15/03 03:19 PM Regulation B - Section 202.9
upstateNY Offline
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Joined: Apr 2003
Posts: 933
New York State
After 20 plus years in compliance I feel really stupid asking this question. With regards to Notices of Adverse Action, we have always required that the bank name, address and telephone number of the branch from where the customer was declined, be included in the notice. We have over 100 branches, so each is required to enter their specific address and phone number. Two questions - 1. In looking at section 202.9, I don't even see the requirement for a telephone number. Is it required? 2. Does the address have to be specific to the branch, or can it simply be the bank's head office? Note that the sample notices in Appendix C are not consistent. Some include a space for phone number, some don't.

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General Discussion
#80517 - 05/15/03 03:41 PM Re: Regulation B - Section 202.9
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
12 CFR 202.9(2) Content of notification when adverse action is taken. A notification given to an applicant when adverse action is taken shall be in writing and shall contain: a statement of the action taken; the name and address of the creditor; a statement of the provisions of section 701(a) of the Act; the name and address of the Federal agency that administers compliance with respect to the creditor...
You definitely don't need a phone number. I see no requirement to make the address specific to the branch
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#80518 - 05/15/03 03:50 PM Re: Regulation B - Section 202.9
Kaos Offline
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Kaos
Joined: Dec 2002
Posts: 130
The telephone number is listed on the sample form C-1. (probably another, "it's not in the reg, but since we put it in the form you have to do it.")

The only other reference I could find is in the Background Summary @ 202.9 when it is required if the bank chooses not to list the specific reasons on the denial and the consumer must contact the bank.

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#80519 - 05/15/03 03:54 PM Re: Regulation B - Section 202.9
Kaos Offline
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Kaos
Joined: Dec 2002
Posts: 130
You beat me to it David! So what is your opinion on the form thing? Another one of those not required/required signature faux pas?

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#80520 - 05/15/03 04:34 PM Re: Regulation B - Section 202.9
Nanwa Offline
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Nanwa
Joined: Oct 2001
Posts: 5,564
Clintonville, WI, USA
We put the main office address because that is the central location where adverse action notices are reviewed and filed. Also, if the customer wrote to us, it would be the quickest place to go for an answer/response. If sent to the branches, there would be a delay in getting it to the correct officer to deal with the situation.
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