My understanding from reading the FTC opinion letter dated 7/14/00 is that we would not be required to give guarantors an adverse action notice (including the FCRA notice) even if we pulled a credit bureau on guarantor and we denied the applicant based on the guarantor's credit report. Is this everyone's understanding as well or is there a more recent opionion to the contrary?

For the purpose of the FCRA AAN guarantors are not applicants but co-applicants/signers are.