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Based on Step 2 below, taken from CFPB Exam Procedures, implies a requirement for policies and procedures regarding consumer requests for information in reponse to an Adverse Action Notice.
Is this a regulatory requirement? I believe my institution directs these requests back to the Loan Officers but there is no set P&P regarding this process. Thanks!Adverse Action Disclosures – Sections 615{a) and {b);
15 U.S.C. 1681m{a) and {b)
1. Determine whether the policies and procedures adequately ensure that the creditor or other
person provides the appropriate disclosures, including the consumer’s credit score as
appropriate, when it takes adverse action against consumers based in whole or in part on
information contained in a consumer report or specified information received from third
parties, including affiliates.
2. Review the policies and procedures of the creditor or other person for responding to requests
for information in response to these adverse action notices.
3. If procedural weaknesses or other risks requiring further investigation are noted, review a
sample of adverse action notices to determine if they are accurate and in technical
compliance.
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