Joint Applicants - Separate Adverse Action Notices

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Question:

We have been told that when we have a joint application and we deny the credit we have to send separate adverse action notices to each applicant, is this true?

Answer:

For Reg B (ECOA), you only need to send an AAN to the primary applicant with the specific reasons for denial. For FCRA, each applicant whose credit report played a part in the adverse action must be sent the FCRA AAN. Even though as an industry standard the ECOA and the FCRA AANs are combined into one form they are two distinct notices that are regulated by two separate regulations.

First published on BankersOnline.com 6/30/08