After conducting a recent audit I realized that our bank should be sending AANs in relation to applications we deny that were sent to us by 3rd parties (where the applicant was not offered or did not accept credit from any creditor). How are other banks handling this? Reg B states that you may contract with the 3rd party that sent the app and they could send the requisite AAN; however, how could we ensure that they were complying with the reg? Would we have to contact the 3rd party in relation to every credit application that we deny and find out if credit was extended by another creditor if we wanted to send the AAN ourselves? Thanks for any input!

Why couldn't you periodically audit them, as you do yourself, to see what denials they have record of?

With regard to indirect dealer applications, we send adverse action notices for anything that we deny or the customer doesn't accept even if they may have gone with another bank.

On your AANs for indirect paper, do you list the third party that you received the application from? Credit was requested for you through us by this dealer...? An old form we used had this information and our new forms do not. Wondering if this is a requirement? I can't find anything in Reg B. I would appreciate any help.