[dgrayson]

Are we required to send a Notice of Adverse Action when the customer withdraws the request? Should we also send the Risk Based Pricing notice in that instance?

[jholzknecht]

An adverse action notice is required when the creditor takes adverse action, not when a consumer withdraws an application.

The risk-based pricing notice is only required when credit is granted on terms that are materially less favorable. No credit is granted when an application is withdrawn.

Are you using the risk-based pricing notice or the credit score exception notice?

[dgrayson]

We are using the Risk Based Pricing

[jholzknecht]

The risk-based pricing notice is not required for a denied loan. So, providing the adverse action notice completes your responsibilities.

[Ginji244]

We send an adverse action notice to all commercial applicants. My question is, if one of the reasons for denial is the guarantors poor credit, do we include the credit score noitce on the AAN that we send to the commercial applicant?

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