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Notices per Applicant

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Question: 
If joint applicants live in same address, do we still need to provide separate notice (i.e. 2 FCRA notice) or can we send 1 notice and since they both live in same address, that would meet the requirement?
Answer: 

Reg B allows its AAN to go to the primary applicant, but the FCRA wants individuals notified separately. As to the FCRA notice, I would send it to one or more applicant(s) even if they’re at the same address. For Reg B requirements (assuming the FCRA doesn’t apply, say you denied them for a non-credit report reason) you could send one Reg B notice.

First published on 06/07/2020

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