When a loan application is denied, compliance isn’t necessarily the first thing many loan officers think about. Why waste time on an 
application that isn’t going anywhere when you could put your time and effort into one that will? While it isn’t wrong to think this way, it’s still very important to ensure that the adverse action compliance requirements in both Regulation B and the Fair Credit Reporting Act are being met.
Did you know that adverse action notice requirements can differ depending on whether an applicant applies for a certain “term” of credit versus a particular “type” of credit? If you don’t offer a particular type of credit, an adverse action notice is not needed. For example, if an applicant applies for a home loan but your bank does not make home loans of any kind. On the other hand, if an applicant applies for a 30-year home loan but your bank only makes 5-year home loans, an adverse action notice IS needed. In this case, you do make home loans, just not the term the customer requested.
Looking for more answers to adverse action notice questions? Join us for our Adverse Action Notices webinar on June 21, 2017.
Published
2017/06/14
Deb Irving
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!