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How much detail is required in the “Description of Action Taken” section of an adverse action notice? – IBA Compliance Connection

How much detail is required in the “Description of Action Taken” section of an adverse action notice?

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Neither the FCRA nor the ECOA require a description of the account transaction or request, though the ECOA regulations require adverse action notifications to include a “statement of the action taken,” which implies that the creditor would have to provide some information about the request on which the adverse action was taken. 12 CFR 1002.9(a)(2). In describing the adverse action, “a creditor may use any words or phrases that describe the action taken on the application.” Comment 1, Official Staff Interpretations, 12 CFR 1002.9. Given that liberal language, we believe that you could safely use generic descriptor, as long as you describe the action taken. You may want to confirm this with your regulator.