My daughter received an adverse action notice from a bank with respect to a credit card. On the adverse action notice, for reasons for denial, they simply listed the credit score factors....the exact same factors repeated on the credit score disclosure portion. I was wondering if anyone does this. I was always coached to stick to the ECOA "model reasons" for denial. Would examiners criticize a practice like this?

From the commentary to 1002.9(b):

"9. Combined ECOA–FCRA disclosures. The ECOA requires disclosure of the principal reasons for denying or taking other adverse action on an application for an extension of credit. The Fair Credit Reporting Act (FCRA) requires a creditor to disclose when it has based its decision in whole or in part on information from a source other than the applicant or its own files. Disclosing that a credit report was obtained and used in the denial of the application, as the FCRA requires, does not satisfy the ECOA requirement to disclose specific reasons. For example, if the applicant's credit history reveals delinquent credit obligations and the application is denied for that reason, to satisfy §1002.9(b)(2) the creditor must disclose that the application was denied because of the applicant's delinquent credit obligations. The FCRA also requires a creditor to disclose, as applicable, a credit score it used in taking adverse action along with related information, including up to four key factors that adversely affected the consumer's credit score (or up to five factors if the number of inquiries made with respect to that consumer report is a key factor). Disclosing the key factors that adversely affected the consumer's credit score does not satisfy the ECOA requirement to disclose specific reasons for denying or taking other adverse action on an application or extension of credit. Sample forms C–1 through C–5 of Appendix C of the regulation provide for both the ECOA and FCRA disclosures. See also comment 9(b)(2)–1."

....wonder how this bank is getting away with that then. It is a very large bank regulated by the cfpb. The factors essentially tell the story. Some of my daughter's huge medical bills after a liver transplant were sold to collection agencies despite the fact that she was making regular small payments.

So the score factors for her score (which has dropped from 805 to 549) are:
Serious delinquency and public record or collection filed.
Too few accounts currently paid as agreed
Number of accounts with delinquency
Time since derogatory public record or collection is too short.

The ECOA Reg B reasons would be:
Delinquent credit
Collection Action

The factors essentially say that.....just not in an ECOA way.

3. The sample forms are illustrative and may not be appropriate for all creditors. They were designed to include some of the factors that creditors most commonly consider. If a creditor chooses to use the checklist of reasons provided in one of the sample forms in this Appendix and if reasons commonly used by the creditor are not provided on the form, the creditor should modify the checklist by substituting or adding other reasons. For example, if “inadequate down payment” or “no deposit relationship with us” are common reasons for taking adverse action on an application, the creditor ought to add or substitute such reasons for those presently contained on the sample forms.

4. If the reasons listed on the forms are not the factors actually used, a creditor will not satisfy the notice requirement by simply checking the closest identifiable factor listed. For example, some creditors consider only references from banks or other depository institutions and disregard finance company references altogether; their statement of reasons should disclose “insufficient bank references,” not “insufficient credit references.” Similarly, a creditor that considers bank references and other credit references as distinct factors should treat the two factors separately and disclose them as appropriate. The creditor should either add such other factors to the form or check “other” and include the appropriate explanation. The creditor need not, however, describe how or why a factor adversely affected the application. For example, the notice may say “length of residence” rather than “too short a period of residence.”

So....since this bank's decision to terminate a credit card is based solely on what they find in a credit report, they have chosen to simply use, as reasons for denial, the factors that cause the score to be low....and that is OK.

I was just wondering if anyone else does this.

Well, I think the reasons they have given are pretty specific and give more detail then condensing them into two Reg. B stock phrases.

Thanks, Randy.

I do too...they appear to be legit/specific and not an actual copy of the score reasons to me. They are simply related.