We are performing an account review on our credit card portfolio for line reduction. Credit was pulled on the primary cardholder only. We are sending two separate Adverse Action notifications to each. For the joint borrower we understand we cannot include the primary's credit info. Do we include FCRA disclosures for the joint borrower as information from the CRA was used in the decision, but it was based on the primary's score? Or just use the ECOA notification?

You must inform all consumers that data from a credit bureau report was used in the denial or adverse event (line reduction), so the co-borrower must be informed of this.

I'd question the decision to only obtain a credit bureau report on the primary cardholder as this could present fair lending concerns in my opinion.