The Fair Credit Reporting Act requires that each applicant (assuming there is a co-applicant) receive an FCRA adverse action notice in the event of an adverse action. Assume that there is a joint application for an installment loan, not secured by real estate (auto loan for example). The loan is denied because after a review of the credit reports of both applicants, the primary applicant previously filed for bankruptcy and the co-applicant has delinquent obligations with creditors. Should each separate notice provided to the applicant and co-applicant only list the reasons specific to their own credit history? In other words, should the applicant's notice only reference the bankruptcy and the co-applicant's notice only reference the delinquent credit obligations? My reasoning for feeling this way is that 1. it protects the privacy of the applicant and co-applicant and 2. it will better inform the applicant and co-applicant of what specific reasons were used in their denial so that each individual may correct them in order to secure the credit in the future. I understand only one would need an ECOA notice but my concern comes specifically from FCRA notice requirements.
In an indirect lending situation if you decline an applicant for delinquent credit and the same day the application comes back in with no changes other than the collateral is a subsequent adverse action notice needed?
A borrower does not meet VA (or FHA) net tangible benefit for refinancing. What would be an appropriate reason for Statement of Denial?
I have a question regarding Notification of action taken. Is the 30 days required to notify a borrower of adverse action counted from the actual application date or when an application is complete (such as when the appraisal comes back and is the value is not sufficient)?
For adverse action notices where the loan requested would not have been secured by consumer real estate, is the credit score exception notice still required?
If I have taken an application and the member does not come back, do I have to send an Adverse Action notice? If so, when? If not, why?
A customer withdrew an application to purchase a car, because he got the financing at the dealer. Do I need to send out any form of adverse actions or cancellation notice? Can I just file the application?
In handling the review of a withdrawal file, the branch stated the reason for withdrawal as the "Applicant changed mind" because they didn't want to pay any fees for closing. Should this have been a denial?
If a customer requests that we eliminate the available credit on their line, do we need to send them an adverse action?
Will decreasing the line or closing a credit card that has not been in use for more than 12 months require an adverse action?