THE HOW TO’S OF DECLINE NOTICES
REGULATION B – ECOA AND FCRA
ADVERSE ACTION NOTICE CHEAT SHEET
|APPLICATION |WHOSE CONSUMER CREDIT REPORT CONTRIBUTED |WHICH SECTION TO COMPLETE ON A COMBINED ADVERSE ACTION NOTICE (ECOA AND FCRA) |
| |TO CREDIT DECISION | |
|One Consumer Applicant | Applicant | Top Section (ECOA) completed |
| |N/A (credit report not used in decision) |Bottom Section (FCRA) completed |
| | |Mark “Disclosure Inapplicable” box on FCRA section. |
|One Consumer Applicant | Applicant | Top Section (ECOA) completed |
| |N/A (credit report not used in decision) |Bottom Section (FCRA) completed |
| | |Mark “Disclosure Inapplicable” box on FCRA section. |
|Joint Consumer Application | Primary Applicant |Primary Applicant |Co-Applicant |
| |Co-Applicant |Top Section (ECOA) completed |Top Section (ECOA) completed |
| |N/A (credit report not used in decision) |Bottom Section (FCRA) completed |Bottom Section (FCRA) completed |
| | |Mark “Disclosure Inapplicable” box on FCRA |Mark “Disclosure Inapplicable” box on FCRA |
| | |section. |section. |
| | | |No notice to co-applicant |
| | | |Note: Co-applicant can receive the ECOA |
| | | |notice, too, but it is not required by Reg. B|
|Joint Consumer Application | Primary Applicant |Primary Applicant |Co-Applicant |
| |Co-Applicant |Top Section (ECOA) completed |Top Section (ECOA) completed |
| |N/A (credit report not used in decision) |Bottom Section (FCRA) completed |Bottom Section (FCRA) completed |
| | |Mark “Disclosure Inapplicable” box on FCRA |Mark “Disclosure Inapplicable” box on FCRA |
| | |section. |section. |
| | | |No notice to co-applicant |
|Joint Consumer Application | Primary Applicant |Applicant |Co-Applicant |
| |Co-Applicant |Top Section (ECOA) completed |Top Section (ECOA) completed |
| |N/A (credit report not used in decision) |Bottom Section (FCRA) completed |Bottom Section (FCRA) completed |
| | |Mark “Disclosure Inapplicable” box on FCRA |Mark “Disclosure Inapplicable” box on FCRA |
| | |section. |section. |
| | | |No notice to co-applicant |
| | |Note: FCRA requires that a notice be sent separately to each applicant even if they are |
| | |married when reason for decline is based upon information contained the credit reports of |
| | |each! |
| | |Recent interpretations/changes in Reg. B clarified that there is no violation of privacy |
| | |to simply send one copy to each disclosing the denial reasons relating to one applicant’s |
| | |poor credit history. |
|Joint Consumer Application | Primary Applicant |Applicant |Co-Applicant |
| |Co-Applicant |Top Section (ECOA) completed |Top Section (ECOA) completed |
| |N/A (credit report not used in decision) |Bottom Section (FCRA) completed |Bottom Section (FCRA) completed |
| | |Mark “Disclosure Inapplicable” box on |Mark “Disclosure Inapplicable” box on FCRA |
| | |FCRA section. |section. |
| | |Indicate as a reason in the other box on the decline notice to the primary applicant: |
| | |“Credit history of co-applicant.” |
|Commercial Application | Guarantor | Top Section (ECOA) completed |
| | |Bottom Section (FCRA) completed |
| | |Mark “Disclosure Inapplicable” box on FCRA section. |
|Commercial Application | Guarantor | Top Section (ECOA) completed |
| | |Bottom Section (FCRA) completed |
| | |Mark “Disclosure Inapplicable” box on FCRA section. |
| | |Notice to be sent President of business. That’s it! It was recently clarified that if a |
| | |commercial credit is declined because of information contained in a credit report of a |
| | |guarantor, the FCRA notice does NOT need to be given to that guarantor, so you would mark |
| | |the box that says, “Disclosure inapplicable,” and would indicate as a reason in the other |
| | |box on the decline notice: “Credit history of guarantor.” |
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