Description:
Adverse action notices may not be anyone’s favorite topic—but they are one of the most important messages a lender sends. They’re usually the only explanation a consumer receives about a credit denial, and the rules behind them are… extensive. Moreover, AANs are one of the most closely examined—and frequently cited—areas in bank examinations.
This webinar takes a clear, realistic, and practical look at adverse action notice requirements under Regulation B, the Fair Credit Reporting Act (FCRA), and fair lending principles. We’ll focus on how the rules apply in actual lending environments, clear up common “do we need a notice here?” questions, and explore how AANs support consistent, non-discriminatory lending.
What We’ll Cover
- When an adverse action notice is required under Reg B, including applications, counteroffers, account reviews, and changes to existing credit
- Reg B notice requirements, including:
- Timing rules and delivery expectations
- What “specific reasons for denial” really means (and what not to say)
- Use of principal reasons and how they differ from credit score factors
- How to handle joint applicants under Reg B
- What to do with “incomplete” applications
- FCRA requirements, including:
- What it means to “use” a consumer report
- Required disclosures when a decision is based in whole or in part on that report
- Credit score disclosures and “key factor” explanations
- How to handle joint applicants under the FCRA
- Fair lending considerations, including:
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- Why consistent adverse action reasons matter across similarly situated applicants
- How vague or overly generic reasons create real fair lending concerns
- The role adverse action data plays in monitoring for disparate treatment
- Why credit scoring, automated underwriting, AI algorithms, and vendor models must be understood and tested for consistency and equitable outcomes (i.e. crack open the Black Box)
Why Does it Matter?
Because adverse action notices sit at the crossroads of compliance, operations, and fair lending. They communicate decisions to consumers, reflect how credit standards are applied, and help demonstrate consistency across applicants. Getting them right helps everyone sleep better at night.
Who Should Attend: Compliance staff, risk managers, loan policy makers, lenders, loan support staff, credit underwriters, and audit.
Presenters:
Rebekah Leonard, CRCM
Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to “make clear, explain, throw light upon”, and describes Rebekah’s desire to illuminate the complexities of compliance with passion and fun. She’s created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource.
Rebekah is currently serving as the VP Director of Compliance for a $7 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she’s covered nearly all of it – customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams.
Rebekah has a bachelor’s degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.
June 3, 2026