Notice of Negative Information

We provide a Notice of Negative Information when a customer closes a loan with the bank. If the bank is only providing this notice should the bank change this and also put this on the statement or is one notice enough? From 623(a) (7) I would have to believe that we should be providing the notice on the statement prior to or no later than 30 days after sending negative information to a CRA.

Thank you!

Look at (7)(A)(ii)

(7) Negative Information
(A) Notice to Consumer Required
(i) In general. If any financial institution that extends credit
and regularly and in the ordinary course of business
furnishes information to a consumer reporting agency
described in section 603(p) furnishes negative information
to such an agency regarding credit extended to a
customer, the financial institution shall provide a notice of
such furnishing of negative information, in writing, to the
customer.

(ii) Notice effective for subsequent submissions. After providing
such notice, the financial institution may submit
additional negative information to a consumer reporting
agency described in section 603(p) with respect to the
same transaction, extension of credit, account, or customer
without providing additional notice to the customer.

(B) Time of Notice
(i) In general. The notice required under subparagraph (A)
shall be provided to the customer prior to, or no later than
30 days after, furnishing the negative information to a
consumer reporting agency described in section 603(p).
(ii) Coordination with new account disclosures. If the notice
is provided to the customer prior to furnishing the negative
information to a consumer reporting agency, the notice
may not be included in the initial disclosures provided
under section 127(a) of the Truth in Lending Act.
(C) Coordination with other disclosures. The notice required under
subparagraph (A) –
(i) may be included on or with any notice of default, any
billing statement, or any other materials provided to the
customer; and
(ii) must be clear and conspicuous.

We provide the Model Form B-1 as a separate disclosure at all loan closings. We also include its language on our paste due notices but providing it at closing is the only time it is required.

. . . with respect to the same transaction, extension of credit, account, or customer without providing additional notice to the customer.

In the case of multiple borrowers, are you all providing the "Notice of Negative Information" to each borrower? So does each borrower receive their own copy, or can they both sign one copy and that would suffice?

If it is on your past due notices, I assume it is addressed to all borrowers. That is all that is required.

We actually provide it on a separate notice form at closing and have the borrowers sign it. I just wasn't sure if it's okay to have that one form signed or if we had to have each borrower have their own copy at closing.