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Small Business Loan NPRM Immanent

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Is use of a general AAN turndown reason such as: “Unqualified co-applicant” considered specific enough for Reg. B compliance or should a general turndown reason like this be avoided?

§ 1002.9(a)(2)(ii) requires a specific and principal reason for the action taken. General statements that the adverse action was based on your internal standards or policies or that the applicant failed to achieve a qualifying score on your scoring system is insufficient. That said, the model forms may be used and if you opt to include additional information, you may do so. If you use “other…” you may want to include enough detail such that there is no doubt as to the reasoning. That is, “Length of employment” is a “canned” reason on the model form. You may use that if the person has been employed for a shorter period than you require, and it may be used if the person is ending employment in the very near future. In the example provided during the webinar, if my applicant had just started their job within the last month, they need more of a track record and more income history. However, if that person has a contractual employment agreement and that is ending, if a disruption of income is highly likely the same reason applies. Document your file and consider documenting the AAN if you believe the applicant will not understand why this is the cause.

First published on 09/05/2021

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