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Agent Bank Responsibilities for Reg B & AAN

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Question: 
As a lender (agent) in a syndication deal, what are the responsibilities of the agent bank with respect to Regulation B (ECOA) compliance specifically related to adverse action notice requirements?
Answer: 

If you are the agent on a syndication deal then you would be the lead for the assignee lenders and likely any such responsibilities would fall to you. It might depend on your agreements with the other banks. But likely it would be treated similarly as any other third party deal.

1002.9(g) Applications submitted through a third party. When an application is made on behalf of an applicant to more than one creditor and the applicant expressly accepts or uses credit offered by one of the creditors, notification of action taken by any of the other creditors is not required. If no credit is offered or if the applicant does not expressly accept or use the credit offered, each creditor taking adverse action must comply with this section, directly or through a third party. A notice given by a third party shall disclose the identity of each creditor on whose behalf the notice is given.
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First published on 03/22/2020

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