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Different Last Names on Joint-List Both On AAN?

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Question: 
There are different last names on a joint application. Should I list both names on the adverse action?
Answer: 

It depends. Here's a short summary:
You must send the primary applicant an AAN. [1002.9(f)]

You must tell each person that has a "bad" credit report that you used their credit report adversely. [ยง 615 of the FCRA]
If the joint applicant's credit report wasn't used or is fine, then 1 notice to the primary is sufficient. If the joint applicant's credit report is bad, then you're going to have to send an AAN to each applicant.

First published on 12/01/2014

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