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Adverse Action Notification Requirements

Question: 
As an FDIC regulated institution I wanted to inquire about notification requirements regarding adverse action. I am unsure if I am reading the regulation accurately in stating that Oral Notification by small-volume creditors is a loop hole to not having to issue a written adverse action notice. We definitely have less than 150 applications. Please advise.
Answer: 

You are correct; Regulation B has an exception for creditors that received fewer than 150 applications in the previous calendar year. Such institutions can provide a verbal Adverse Action Notice (instead of a written notice) and still be compliant with Regulation B. This exception does not conflict with any other federal regulation.

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First published on 12/10/2017

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