Answer:
Yes. The FCRA defines the term adverse action as an action taken or determination that:
• Is made in connection with an application that was made by, or a transaction that was initiated by, any consumer, or in connection with a review of an account under section 604(a)(3)(F)(ii); and which is
• Adverse to the interests of the consumer.
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2017 Providing Accurate and Timely Adverse Action Notices