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#1719685 - 07/12/12 10:27 PM AAN to co-signer
pat robbins Offline
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Joined: Jun 2007
Posts: 87
Oklahoma
From reading previous threads we are not required to send a AAN to a co-signer. Is it a problem if we did send one? We sent separate AANs; one to the applicant and one to the co-signer. We pulled a credit report on the co-signer and did disclose his credit score on his AAN but gave no info on the applicant. Is this OK?

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#1719708 - 07/13/12 11:45 AM Re: AAN to co-signer pat robbins
KPOC Offline
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Posts: 460
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You are correct, cosigners do not receive AANs.

"Under section 701(d)(6) of the ECOA and § 202.2(c) of Regulation B, only an applicant can experience adverse action. Further, a guarantor or co-signer is not deemed an applicant under § 202.2(e). Sections 603(k)(1)(A) and 603(k)(1)(B)(2) of the FCRA provide that adverse action has the same meaning for purposes of the FCRA as is provided in the ECOA and Regulation B in the context of a credit application. Therefore, a guarantor or co-signer would not receive an adverse action notice under the ECOA or the FCRA." [Regulation B; Docket No. R-1408]

Since you sent each consumer an AAN with their own credit score only, I don't see this as a problem.

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#1719840 - 07/13/12 03:14 PM Re: AAN to co-signer pat robbins
Andy_Z Offline
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I agree with KPOC. You haven't harmed the bank with the notice, but it wasn't required.
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#1719870 - 07/13/12 03:49 PM Re: AAN to co-signer pat robbins
pat robbins Offline
Member
Joined: Jun 2007
Posts: 87
Oklahoma
Thanks.

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