A lender sends a consumer an otherwise complete Regulation B denial notice, including the required ECOA and federal agency information, and discloses the right and procedure to request specific reasons rather than listing them. The applicant requests the reasons 40 days after notification. Is this approach permitted, and when must the lender provide the reasons?
Correct Answer
B) Valid notice: she had 60 days to ask, and reasons are due within 30 days
B. The request is timely; the creditor has 30 days to provide reasons. Day 40 is within the applicant’s 60-day request window. The creditor’s response clock runs from the request, not from the original denial. Scope and exceptions: The question assumes the initial notice properly disclosed this alternative. Source: 1002.9(a)(2)(ii) — https://www.consumerfinance.gov/rules-policy/regulations/1002/9/
Why This Is the Correct Answer
B. The request is timely; the creditor has 30 days to provide reasons. Day 40 is within the applicant’s 60-day request window. The creditor’s response clock runs from the request, not from the original denial. Scope and exceptions: The question assumes the initial notice properly disclosed this alternative.
Why the Other Options Are Wrong
Option A: Valid notice, but her request is late: the window to ask closes at 30 days
It shortens the request window.
Option C: Invalid notice: specific reasons must always appear in the notice itself
It eliminates the permitted request-based alternative.
Option D: Valid notice, and the reasons are due within 60 days of her request
It doubles the response period.
Exam Tip
Applicant: 60 days to ask. Creditor: 30 days to respond.
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