Reason For Adverse Action?

Posted By: Likes to Comply

Reason For Adverse Action? - 11/09/11 05:20 PM

It's our bank policy not to provide credit cards to non customers. We had a walk-in apply for a credit card. The credit report was pulled before anyone checked to see if this person was a customer.

The credit score was 672 (within our range). However, 4 of the credit cards on the report are maxed out. 3 new credit cards were opened in the last 6 months for a total of $14,000. One of these cards is maxed out at $8,000.00

We want to deny this application. Is it too late to use the non-customer reason, since we have already pulled a credit report?

Can the other factors in the credit report be used as reasons? if so, how could i state that appropriately?

Thanks in advance for your help!
Posted By: rlcarey

Re: Reason For Adverse Action? - 11/09/11 05:54 PM

I wouldn't provide credit cards to non-customer's either I would require them to open a credit card account first and become a customer before I provided them a card smile

You need to apply your normal credit card underwriting criteria and let them know speciifically why they did not qualify. If the only reason is that you don't open credit cards for indiviuduals that do not have other relationships with the bank, then that is the reason. Of course, once they opened that checking acccount for $10 - you would have to grant them the card.
Posted By: Likes to Comply

Re: Reason For Adverse Action? - 11/09/11 06:33 PM

Do I have to use only the reasons listed on the model AAN or can I use something like Amount owed on recently opened accounts too high? or Amount owed on revolving accounts is too high?
Posted By: rlcarey

Re: Reason For Adverse Action? - 11/10/11 01:29 PM

You need to specifically describe the reason. If your standard underwriting requirements address these points and they do not qualify under that specific standard, then that is what you would say. You should not be applying a standard to this applicant that you don't apply to all others, as if they are in a protected class, you are going to have fair lending issues.