Adverse action notice generation for lenders
Generate ECOA and Regulation B credit denial notices from your loan data. Software tracks the clock and fills approved language. Compliance owns the reason mapping and reviews exceptions. Credit notices only, not employment.
Example Credit Union, 100 Sample Road
Description of Account, Transaction, or Requested Credit: Auto loan
Description of Action Taken: Credit denied
Part I - Principal Reason(s) for Credit Denial: Excessive obligations in relation to income. Delinquent past or present credit obligations with others.
Part II - Our credit decision was based in part on a report from Test Reporting Agency, 555-0100. The agency played no part in our decision and cannot supply specific reasons.
Your credit score: 000. Range, key factors, date, and provider appear below.
You may get a free copy of your report within 60 days, and may dispute its accuracy.
The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants...
| Application | Clock | Status |
|---|---|---|
| Sample A | Day 24 of 30 | Ready |
| Example B | Day 29 of 30 | Compliance |
| Test C | Day 70 of 90 | Watching |
How it runs.
Notices go out late, or the reasons do not match the decision. A checked box on a sample form fails if it was not the real factor.
Decision data
Action taken, decision date, reason codes, and credit report used.
Your dataClock and reasons
30-day clock runs. Reason codes mapped to approved language.
AutomatedCompliance reviews
Compliance owns the mapping and clears any unmapped reason.
A personNotice and record
Notice mailed or delivered. Date and content stored with the application.
Automated
Loan origination system / Regulation B Appendix C / Credit report data / Mail or e-delivery vendor
The rules and limits.
- The clock
- 30 days after a completed application, or after adverse action on an incomplete one. 90 days after a counteroffer not accepted. Notice counts when delivered or mailed.
- ECOA content
- Action taken, creditor name and address, ECOA notice, federal agency, and specific reasons or the right to request them. Internal standards are not a reason.
- How many reasons
- Regulation B sets no number, but commentary says more than four is not likely to help. Scored systems must use factors actually scored.
- FCRA 615(a)
- If a consumer report was used: score and key factors, agency name and phone, that it did not decide, a free report within 60 days, and dispute rights.
- Sample forms
- Proper use of Forms C-1 to C-4 meets the notice rule. Checking the closest listed reason fails if it was not the real factor.
What a person does.
- Compliance owns the map from decision codes to notice language.
- A person clears any reason with no approved text.
- Counsel approves the letter template before any notice goes out.
- Software selects approved reasons. It does not write new ones.
Where we stand: we have not shipped this. It uses the same pattern as our data sync and reporting work.
Common questions.
Does this make us compliant?+
No. It helps track timing and fill approved language. The creditor stays responsible for accurate reasons, the notice text, and delivery. Have counsel approve templates.
Does this cover employment adverse action?+
No. This page covers credit notices under ECOA, Regulation B, and FCRA section 615(a). Employment screening notices follow different steps and are not covered here.
Can it connect to our loan origination system?+
It depends on your vendor and contract. Some vendors need the lender to set up an API user before a partner can connect. Without API access, a daily export can do the job.
Sources
General information, not legal, tax, or compliance advice. Rules change; confirm against the current source and your own advisers.
Bring us your version of this.
Intro calls are 30 minutes, free, and useful even if we never work together. We'll be honest about whether this is the right fit for your finance team.