When sending out a Statement of Credit Denial for a Commercial Loan, does it need to state the "Key Factors" for denial from the Credit Report?

This is covered in § 1002.9(a)(3) and (b)(2).

Depending on the gross revenues of the business, how you provide the notice of action taken, and when and how you need to provide the reasons for adverse action can vary, as can any requirement to provide a notice of the right to ask for the reasons for adverse action.

Take a look HERE for further details.

Key factors from credit report would be FCRA requirements. FCRA adverse action only applies to consumers, but it defines consumers as individuals, so if the applicant was an individual (not guarantor), and credit report was used in decision, then FCRA requirements (including key factors) would apply. If the applicant is an entity, then FCRA AAN rules would not apply (but ECOA still would).

https://www.consumercomplianceoutlo...ion-notice-requirements-under-ecoa-fcra/

"If any person takes any adverse action with respect to any consumer that is based in whole or in part on any information contained in a consumer report, the person shall [...]" Section 615(a)

"The term “consumer” means an individual." Section 603(c)