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AAN? We don’t make those loans.

Answered by: 

Question: 
During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?
Answer: 

A denial of a PPP loan for some reason which disqualified the borrower would, but Reg B provides that no unlawful discrimination results if the bank does not offer the type of credit being requested. That doesn’t mean “loan terms” but does mean the credit plan itself. Since your bank wasn’t making these SBA loans, no AAN was required.

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First published on 06/13/2021

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