I have been told conflicting advice about the adverse action notice. Supposedly, these are people who are in the know. However, I am a compliance manager with no staff and don’t have a clear answer to my concerns.
First, I want to know what information I need from a credit bureau to issue an adverse action notice.
Secondly, I want to know what information I need from third parties that are not credit bureaus for me to issue the adverse action notice.
Third, and the biggest issue for me, I want to know who we should notify when multiple applicants are on a loan application. I say this is the biggest issue because this is the one on which I get a lot of conflicting advice.
So, here are my questions.
What is required for adverse action based on credit bureau information?
What is required for adverse action based on third parties?
And, who is supposed to get the adverse action notice when the loan is for multiple applicants?