A denial letter dated 9 June gives the specific reasons and the name and telephone number of the officer who can discuss them, but says nothing about the prohibition on discrimination. Does this letter satisfy Regulation B's adverse-action notice content requirements?
Correct Answer
C) Incomplete: the required ECOA nondiscrimination notice is missing
C. Specific reasons do not excuse omission of the ECOA notice. Regulation B requires multiple items in the written adverse-action notification; the reasons are only one part. The required content also addresses the action, creditor identity, nondiscrimination notice and responsible federal agency. Scope and exceptions: The full provision includes either specific reasons or a compliant notice of the right to request them. FCRA disclosures can be separate additional obligations; do not merge the two statutes. Source: 1002.9(a)(2), (b)(1) — https://www.consumerfinance.gov/rules-policy/regulations/1002/9/
Why This Is the Correct Answer
C. Specific reasons do not excuse omission of the ECOA notice. Regulation B requires multiple items in the written adverse-action notification; the reasons are only one part. The required content also addresses the action, creditor identity, nondiscrimination notice and responsible federal agency. Scope and exceptions: The full provision includes either specific reasons or a compliant notice of the right to request them. FCRA disclosures can be separate additional obligations; do not merge the two statutes.
Why the Other Options Are Wrong
Option A: Incomplete: the letter must also state the applicant's 3-digit score
It substitutes a credit-score issue for the missing Regulation B notice tested here.
Option B: Complete, provided the officer named can supply the ECOA notice on request
Availability on request does not supply a required part of this notification.
Option D: Complete: specific reasons are the substance and satisfy the section
Specific reasons alone do not satisfy all content requirements.
Exam Tip
A strong explanation of denial is not a substitute for a complete notice.
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