We have an automated application process for business credit cards where if a decline decision is made, the software will send an email to the applicant of credit denial. For a large business, Reg B requires notification of the action taken. If our email states “declined” and gives the reasons, would it also need to include the ECOA Notice? Reg B says that if the applicant makes a written request for the reasons, then include the ECOA Notice. I’m just not sure if the ECOA Notice should be included in the email if it happens to also list the reasons.

If the email says only to contact us for the reasons, it would not need to include the ECOA Notice. 1002.9(a)(3)(ii)(B)

How do you limit access to your credit card application portal to only those business with more than $1MM in annual revenues?

But IMHO, if you give them the reasons then you have to give them the notice.