[kcco]

Now that we are required to report reasons for denial in 2018, how do we handle the commercial loans (with revenues under 1mill) that do not typically require a denial in writing..ie and adverse action. Since we are not required to give a notice, should we create some type of form with the reason(s) for denial? Should we start giving an AA? Please advise as to the best process/procedure for commercial loans that are HDMA reportable.

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[rcooper]

I assume your files already include information documenting the reason for the denial. If it does not, you will want to create a process to document that in the file. The process you choose is up to you.

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