Dan, that makes perfect sense. I neglected the
"in a form the applicant may retain."Perhaps I can add that as page two and have the signature disclosure acknowledge that they received that page?
Garret01, you're looking at this section right?
(ii) With regard to a business that had gross revenues in excess of $1 million in its preceding fiscal year or an extension of trade credit, credit incident to a factoring agreement, or other similar types of business credit, a creditor shall:
(A) Notify the applicant, within a reasonable time, orally or in writing, of the action taken; and
(B) Provide a written statement of the reasons for adverse action and the ECOA notice specified in paragraph (b)(1) of this section if the applicant makes a written request for the reasons within 60 days of the creditor's notification.
I guess my interpretation was that we only need to provide the ECOA and reasons in a written form if they request it (after the officer has provided an oral notice).
This is all coming about because I’m having a hard time keeping officers on track with then they receive a complete application, and how they work with these applicants. They may be back and forth on deals for structuring, collateral, etc. and not even submit for an approval before the 30 days is up. Then I have to convince them to send an Counter Offer/AA Notification while they continue to work it, etc.
Maybe back to the drawing board on this.
Maybe I’ll just track it myself and work off of that. I just hate to mess up Reg B. Adverse Action regulations because they’re really pretty easy to comply with (compared to some others anyway)