Customized AAN Reason??

With regard to indirect auto lending, we like to see other installment trades in the applicant's credit bureau. In a situation where we don't see this, can we use a customized reason for turndown (meaning outside the typical sample Reg. B AAN reasons), such as "lack of comparable auto or installment loans"? Or is something like this not permissible under Reg. B? Often, there are other primary reasons for the turndown (and we would disclose them all), but this may be a factor in our credit decision as well.

You have to disclose the denial reasons and if that is a specific underwriting criteria that you use, then you would have to describe it if is was a main contributing factor. The factors listed in the models in Regulation B are nothing but examples.

If the reasons listed on the forms are not the factors actually used, a creditor will not satisfy the notice requirement by simply checking the closest identifiable factor listed. For example, some creditors consider only references from banks or other depository institutions and disregard finance company references altogether; their statement of reasons should disclose “insufficient bank references,” not “insufficient credit references.” Similarly, a creditor that considers bank references and other credit references as distinct factors should treat the two factors separately and disclose them as appropriate. The creditor should either add such other factors to the form or check “other” and include the appropriate explanation