I recently listened to your “Providing Accurate and Timely Adverse Action Notices” webinar from 7/12/2018. Your discussion on slide page 35 indicated that an Exception Credit Score Notice needed to be provided when Adverse Action is taken.
Seems like that is not the case, based on what the Fed indicated in the preamble…. ??
Creditors also do not need to provide an exception notice to a consumer if one of the other exceptions applies. For example, consumers who apply for and receive a specific rate or who receive an adverse action notice pursuant to the exceptions under § __.74(a) and § __.74(b), respectively, are not entitled to a notice.
And 1022.74b exception is…
(b)Adverse action notice. A person is not required to provide a risk-based pricing notice to the consumer under § 1022.72(a), (c), or (d) if the person provides an adverse action notice to the consumer under section 615(a) of the FCRA.
Can you please address and clarify??
This topic was modified 1 month ago by johnr. Reason: typos
The slide you reference indicates, in Footnote 1, that a risk-based pricing notice (RBP) is not required on a denied application. But when an exception notice is used it must be proved within three days of receiving the score. So, unless an adverse action notice is provided with three days, the borrower will receive both the exception notice within three days and the Adverse Action notices within 30 days. If an AAN is given within 3 days of receiving the score, then only the AAN is needed.