AAN Joint Applicants

How is everyone handling adverse action notices for joint applicants when using combined ECOA, FCRA notice. Since revised Reg B clarified that the ECOA notice must list specific reasons for the action regardless of whether the reason(s) pertain to applicant A or B, the notice may be confusing. However, we spoke with FRB attorney and they stated that B does not require lenders to identify which reason pertains to which applicant. Throw in FCRA requirements and the AAN may be "messy". Our loan platform automatically generates the combined AANs for each applicant that identifies all the reasons, without identifying which reason pertains to which applicant. Anyone doing anything differently? Anyone been through an exam where the process was tested?

I found this thread as I am having a similar discussion. A lender has an application for a father and son, they were both credit scored but the son had no credit history and the father ended up declined due to his credit history. The lender wants to know if they send the AAN to the son who was to be the primary or to the father? Their concern is that if they send it to the son then he will see his father's credit issues and are concerned that the father may complain or allege privacy concerns. We have been going on the understanding that if we use a combined Reg B/FCRA notice then according to Reg B we only have to provide the notice with all reasons to the primary applicant. Just not comfortable with this and would appreciate some other input. Thanks.