Adverse Action Reasons due to CR on Joint App

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    If we pull credit reports on both of the 2 applicants and the reason for the adverse action is related to the credit report, must the reasons on each applicants’ adverse action notice only be related to that applicant?

    For example, if the primary applicant has delinquencies, collections, and a bankruptcy and we use those reasons on their adverse action notice, can we use the same reasons on the co-applicant if their report only had delinquencies but not collections or bankruptcy? Or would we only be able to show the delinquency reason for the co-applicant?

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