We provide a copy of the credit report and a credit score exception notice, along with the adverse action notice, to every applicant we deny. On our adverse action notice, in place of providing the key factors that contributed to the low score/denial, we'd like to provide a statement that says "refer to credit report," since these reason appear on that report anyway. Is this compliant?

IMHO - No. These two notices are stand alone.

"refer to credit report"? Are you giving them a copy of the credit report?

Yes - we give a copy of the credit report, as well as the credit score exception notice.

Thanks for your response.

Why would you be handing the customer a copy of the credit report? You need to check your contract with your CRA to make sure you are allowed to do that......

I agree that this will not work. The bank must state the factors, not expect the customer to figure it out.

Credit reports often include a LOT of information, and are likely to obscure in the detail the principal reasons a creditor is likely to decline a credit request. It's the credit bureau's job to provide you, the creditor, with data you can use to inform a credit decision. It's your job as the creditor to determine what are your principal reasons for adverse action. You can't push that back on the credit bureau.

I'm really surprised that you can provide a copy of the actual credit report. Our contracts with our credit vendors are very explicit that we cannot provide an actual copy of the report to the consumer.