Unpacking Adverse Action Requirements

Accurate communication with applicants and existing borrowers is critical, especially when the application is being denied or the loan terms are changing for a pre-existing credit arrangement. Adverse action notices are designed to communicate concern to applicants and borrowers. Along with being an informational notice, a loan denial triggers Regulation B requirements, and depending on the reason for denial, a Fair Credit Reporting Act (FCRA) notice may also be mandated. Examiners have long identified weaknesses in the handling of loan applications that never yield an originated loan. This webinar will focus on pinpointing when an inquiry becomes an application, important timing requirements, and proper completion of the adverse action notice and other notification options, including a counteroffer.