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When must we notify applicants of an adverse action? We thought it was required in three days. – IBA Compliance Connection

When must we notify applicants of an adverse action? We thought it was required in three days.

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A creditor must notify an applicant of an adverse action with 30 days after receiving a completed application. 12 CFR 1002.9(a)(1)(i). You may be thinking of the early disclosure rules, which require banks to send out the early disclosure and good faith estimate within three business days. 12 CFR 1026.19(a)(1)(i)12 CFR 1024.7(a). You may also be thinking of the Regulation Z requirement that creditors provide a change in terms notice within three business days of after it “prohibits additional extensions of credit or reduces the credit limit” on a home-equity plan. 12 CFR 1026.9(c)(1)(iii).