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#2047789 - 11/03/15 06:50 PM FCRA AAN for Co-Applicant
lcc Offline
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Joined: Oct 2012
Posts: 127
I have a couple of questions regarding adverse action notices:
1. In the situation of a consumer applicant and co-applicant, we pull a consumer credit report on both individuals, but our underwriting system only allows us to evaluate on the applicant's credit score, not the co-applicant's credit score. Therefore, we would not have a situation where we would deny an application based on the co-applicant's credit score. However, we could have a situation where we would deny an application based on other derogatory credit information we obtained from the co-applicant's credit report, such as a charge-off, repossession, foreclosure, or even that their DTI exceeds the max DTI. My question is this - If we deny an application based on derogatory information we obtained from the co-applicant's credit report (i.e. charge-off), but not on the co-applicant's credit score itself, do we have to include the co-applicant's credit score, range of scores, etc. on the adverse action notice to the co-applicant?

2. What happens if the scenario above is a co-signer or a guarantor, instead of a co-applicant? Would we even need to send an adverse action notice to a co-signer or guarantor (Reg. B or FCRA) if the denial was based on information obtained from the co-signer or guarantor's consumer credit report?

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#2047850 - 11/03/15 09:08 PM Re: FCRA AAN for Co-Applicant lcc
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
1. No. Their score was not a factor in the adverse action.

2.. No. The co-signer/guarantor is not being denied credit.
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The opinions expressed are mine and they are not to be taken as legal advice.

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