I need a refresher on how to complete adverse action forms for Reg B and FCRA.

Let’s say we have an application for credit with two applicants. We pull a credit report on both. Applicant A has good credit but Applicant B has bad credit. Since the decision was based on information from a credit report both would get a separate form.

I know how to complete Applicant B’s form by completing Part I and Part II with the credit score section and key factors.

My question is how do I complete the form for Applicant A when we are denying based on Applicant B's bad credit? Do we:

1)complete Part I and choose reason “other” and put “co applicant does not qualify” and leave Part II blank?

or

2) do we complete part I and use "other - co applicant does not quality and also mark the same reasons used on Applicant B's denial and leave Part II blank?

The reasons you give for denial should be the same on both Reg. B AANs if you send two.

Why send Applicant A a Reg. B adverse action notice? You only need to send one under Regulation B. Send it to the person with crappy credit.

Thank you for getting back with me.