You should provide all of the applicants with adverse action notices, even if they had applied jointly with other applicants, because you have pulled credit reports on all of them. 

As explained in a helpful Federal Trade Commission  (FTC) advisory opinion, while Regulation B requires that you send an adverse action notice to only the primary applicant, the Fair Credit Reporting Act (FCRA) requires you to send an adverse action notice to all applicants. If you are using an adverse action form that combines the Regulation B and FCRA requirements, you must send the combined notice to the primary applicant, and you must send either an FCRA notice or the combined notice to any joint applicants. 

For resources related to our guidance, please see:

• Regulation B, 12 CFR 1002.9(f) (“When an application involves more than one applicant, notification need only be given to one of them but must be given to the primary applicant where one is readily apparent.”)

• FCRA, 15 USC 1681m(a) (“If any person takes any adverse action with respect to any consumer . . . the person shall (1) provide oral, written, or electronic notice of the adverse action to the consumer . . . .”)

• FTC Advisory Opinion to Stinneford (July 14, 2000) (“When there are two applicants a creditor cannot send a combined ECOA/FCRA adverse action notification to only the primary applicant if the application is denied, even in part, based on information in a co-applicant’s consumer report. In that circumstance, the co-applicant has been the subject of ‘adverse action’ and must be provided his or her own separate notification to satisfy the requirement of Section 615(a) of the FCRA. If the creditor has provided the ECOA-required information specified in Section 202.9(a)(2) of Regulation B to the primary applicant, it need not be included in the FCRA notice provided to the co-applicant.”)