Non-real estate loan applicants can use our online form to request a loan. Based on their address we will know if they are in or out of our market area. In some cases an online request is stopped before a credit report is pulled and the person is not allowed to complete the application because they receive a message saying they are outside our market area. The bank does not send any other other notification. Are we required to send an adverse action notice if the bank's practice is to not make these type loans outside of our service area?
Can we do an internal raffle (selling tickets for a chance to win a prize) to benefit a non-profit organization?
Joint application is received by the bank with one applicant having excellent credit and the other having terrible credit. For AAN purposes, if we provide the specific reasons for turndown to the terrible applicant such as repossession, delinquent past/present credit obligations with others, etc. and then provide an AAN to the excellent applicant, we should re-state repossession, delinquent credit obligations, etc. on the excellent applicant’s AAN as well - even though these reasons don't specifically apply to the excellent applicant himself, but are the primary reasons for the turndown. Correct?
Reg B: Do you need to disclose the Bank's name and address to a declined business applicant?
Is it mandatory to give the customer an adverse action notice when turned down for a deposit account? If so, should the agency we collected the info from provide the forms?
When do you have to send out a Adverse Action Notice on Commercial Loans?
I am preparing an adverse action notice for a denied application, but the applicant does not have a score on their credit report.How do I complete the credit score portion of the adverse action notice when there is no score? Can this section be omitted?
What is the regulatory requirement for declining a customer the Bill Pay Service?
We pull a report (not a credit report) prior to opening checking accounts for new clients. This report only contains information on checking account closures, it is not a credit report, nor do we use this report in credit decision. We have recently changed the adverse action from when we refuse to open a checking account because of information contained in this report, but it mirrors the form we give to our loan clients. Where do we find, definitively, what needs to be included in this Adverse Action notification. Again, there is no credit decision, nor is there any credit information contained in the report received.
Are adverse action notices issued when credit card lines of credit are closed for inactivity?