Loans Denied Due to Criminal Subpoenas

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Question:

What can we put down as the reason for denial on the Adverse Action Notice, for loans denied due to criminal subpoenas? Can we select "Other" and specify "BSA concerns"?

Answer:

My suggestion would be to provide the generic adverse action notice without specific reasons included but giving the applicant the right to request the reasons for the denial. See 1002.9(a)(2)(ii) and Appendix C-5. I would suspect there is a high likelihood that you will not hear from them requesting the reasons.