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Reg B Disclosure for Declined Applicant

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Reg B: Do you need to disclose the Bank's name and address to a declined business applicant?

The requirements for all AANs are spelled out in section 1002.9(a). Subsection (a)(2) gives the contents of all AANs. Subsection (a)(3)(i) indicates you must give all of the information required by (a)(2) to "small businesses" except two things. The name and address of the bank are not exempt. Therefore, they would need to be provided. Subsection (a)(3)(i)(C) does indicate that if the application is by phone, then you wouldn't have to provide the name and address. Subsection (a)(3)(ii) addresses "large businesses." It does not list the name and address of the bank as a requirement but does indicate the applicant can make a written response for the reasons for denial. If the bank didn't provide their name and address, how would the denied applicant contact the institution to get the reasons?

First published on 05/04/2015

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