Information to Include in AAN

Posted By: ACBbank

Information to Include in AAN - 07/06/21 03:44 PM

Our AAN's include the required verbiage going back to the model notice(s). It has the standard verbiage for Part I and Part II. However, for Part II it stops at at "If you an questions regarding this notice....". Audit is indicating that we need to include some additional verbiage that starts with "We also obtained your credit score from the consumer reporting agency and used it in making our credit decision...." (We do have the ECOA Notice included).

In this instance a credit report was pulled and was part of the underwriting process. Looking at the regulation I would tend to agree with audit but this is outside of my area of expertise.
Posted By: raitchjay

Re: Information to Include in AAN - 07/06/21 03:47 PM

If the denial is based on information in the credit report, then you need that box checked and the credit bureau information below that...and the credit score information below that. However, if you are denying for a non-credit based reason (such as insufficient collateral), you wouldn't want or need any of that. Hope that helps.
Posted By: ACBbank

Re: Information to Include in AAN - 07/06/21 03:54 PM

Well this notice has the "Our credit decision on your application was based in whole or in part on..." However, the denial reasons were collection action or judgement and delinquent past or present credit obligations with others. Thoughts on whether we need the additional verbiage?
Posted By: raitchjay

Re: Information to Include in AAN - 07/06/21 03:58 PM

Those are credit based reasons, so you'd need the box checked indicating the decision was based on information from a consumer reporting agency, the consumer reporting agency info, and the credit score information. Is that the additional verbiage you mean?
Posted By: raitchjay

Re: Information to Include in AAN - 07/06/21 03:58 PM

I'm heading out the door for lunch, so hopefully someone else can chime in to help.
Posted By: rlcarey

Re: Information to Include in AAN - 07/06/21 04:03 PM

I do not really understand. ABC - are you saying that the bank used a credit report in the decision making process and failed to include Part II on the adverse action notice?
Posted By: ACBbank

Re: Information to Include in AAN - 07/07/21 06:25 PM

Sorry if I'm not be clear guys, this isn't really my area. Yes, that is what it looks like Randy.
Posted By: rlcarey

Re: Information to Include in AAN - 07/07/21 06:50 PM

Then if you used information contained in the credit report in your decision to deny, then yes - that is a problem.
Posted By: ACBbank

Re: Information to Include in AAN - 07/07/21 06:59 PM

As I thought it was. Thanks Randy.
Posted By: CRL

Re: Information to Include in AAN - 07/22/21 10:11 PM

Can I get clarification, if a credit report is obtained and a denial is based in part from information in the credit report, is there ever a time we would NOT include the second paragraph about the credit score with the required score, range, factors, etc? We're reviewing our procedures and Laser Pro allows including the "credit decision based on a report..." language, but then you need to also check the box to include the credit score language.

I thought if you obtained a credit report and the denial was based on the report, you must include the credit score language?
Posted By: CRL

Re: Information to Include in AAN - 07/22/21 11:16 PM

Nevermind - I just realized not everybody obtains credit scores with their credit reports. So obviously Laser Pro needs to allow for that option to not include the credit score language on the AAN.

I tried to delete my post, but was unable to do so, sorry!