Is an Adverse Action Notice required to be provided to a cosignor? New Computer program being implemented and the Company is saying its not required. We have always sent them in the past, bur I can't find where Reg B indicates it has to be done. Any help appreciated.

An AAN required by the ECOA does not have to be sent to the co-signer, only to the primary applicant. But the AAN required by the FCRA does if information from their credit report was used in the denial.

If a CBR is obtained but does not play a part in a denial (e.g. customer has good credit, but is given reduced counter-offer based on LTV), must the FCRA notice be provided in the AAN (we use a combined notice for ECOA & FCRA)?

No - only if the credit decision was based in whole or in part on the credit report would the FCRA adverse action notice be applicable.