Whether or not notice must be provided will depend upon whether the consumer is a co-signer or a guarantor of the obligation. If the consumer is a guarantor, no adverse action notice is required under ECOA or FCRA. FTC Staff Opinion Letter dated July 14, 2000, from Christopher Keller, Attorney, to Ryan Stinneford, Esq. addresses this issue.
This one was new to me until our latest declined commercial applications audit.
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Robert Marx
Opinions stated are not necessarily that of my employer.