Under Reg B, you do have to give a specific reason for the denial, but perhaps a better way to proceed would be to notify the applicant that you deem the application to be incomplete because they have failed to provide information that would allow you to verify identity. Spell out what they would need to provide. If they can't do it within the requisite timeframe, you consider the application incomplete. That way, if the reason you can't verify identity is because the person applying is an imposter, you aren't paving the way for him/her to obtain a copy of the victim's credit report.
Adverse Action Notice Verbiage
Can we use a reason such as 'unable to verify identity' on an adverse action notice? Is that allowable under Reg. B?