When denying co-applicants with the same address, can Adverse Action notices be sent in the same envelope, or must they be sent separately?

Separately.

1002.9(f) Multiple applicants. When an application involves more than one applicant, notification need only be given to one of them but must be given to the primary applicant where one is readily apparent.

It is going to depend if you combine the required FCRA credit score disclosure with the AAN.

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

The requirements are different for multiple applicants. According to Regulation B, if multiple applicants submit an application, notice need only be given to the primary applicant if the primary applicant is readily apparent.6 In the case of multiple applicants under the FCRA, the statute has been interpreted to require notice to all consumers against whom adverse action is taken if the action taken was based on information in a consumer report.7 If the applicants’ credit scores were used in taking adverse action, each individual should receive a separate adverse action notice with the credit score and related disclosures associated with his or her individual consumer report; however, an applicant should not receive credit score information about a coapplicant. Regulation B does not prohibit delivery of an adverse action notice to each applicant. If applicable, financial institutions can provide a combined notice of adverse action to all consumer applicants to comply with multiple-applicant requirements under the FCRA, provided a credit score is not required for the adverse action notice because a score was not relied upon in taking adverse action.

Common violations related to credit score disclosures. Violations involving the FCRA’s requirement to include credit score information in adverse action notices typically involve failing to recognize when the requirement applies. The disclosure requirements are triggered when a credit score is used by a person in taking adverse action.29 Some violations have occurred when persons interpreted the term “use” too narrowly to include only situations when adverse action is solely or primarily based on the credit score. Similarly, other violations have involved persons incorrectly providing additional credit score disclosures only in cases when a minimum credit score was established. To avoid these violations, a person must provide the additional credit score disclosures whenever a credit score is used in the decision to take adverse action.

Thank you Dan; I knew that notice to only one applicant wasn't correct.

My institution send the FCRA credit score disclosure with the AAN. So in the case that both applicants have the same mailing address, these should be sent in separate envelopes, addressed to the applicants individually to best be in compliance?

Yes, bingo!

So glad you got the correct answer.

Well, my answer was not incorrect. But they asked about an adverse action notice, that is governed under Regulation B. The FCRA disclosures are governed under the FCRA and there were not mention that credit scores were involved. It is important to include all information in your questions.

Do you agree that FCRA credit score disclosures should be sent separately to each applicant, even if their mailing addresses are the same?

Thank you for your help!

Well, if you refer back to what Dan contributed:

"If the applicants’ credit scores were used in taking adverse action, each individual should receive a separate adverse action notice with the credit score and related disclosures associated with his or her individual consumer report; however, an applicant should not receive credit score information about a coapplicant."

While you can never assure that they will not open each other's mail, putting them in the same envelope will almost ensure that one of them will see the other' applicant's information.