Build an adverse action notice workflow compliant with ECOA Regulation B and FCRA Section 615(a)

Steps

1. Identify which regulation applies: ECOA Regulation B (12 CFR §1002.9) covers the timing and content of notices for all credit decisions; FCRA §615(a) adds disclosure requirements when a consumer report was used in the decision
2. Capture the principal reasons for the adverse action from your decisioning system (up to four reasons are required under Reg B; they must be specific and not simply reference internal score thresholds)
3. If a consumer report was used, add the consumer reporting agency name, address, and phone number; and the consumer's right to obtain a free copy of the report within 60 days and dispute inaccurate information
4. Deliver the notice within 30 days of receiving a completed application (Reg B) using an approved method — written notice mailed or delivered electronically with E-SIGN consent
5. For AI/ML-model-driven decisions, ensure reason codes are specific to the consumer's actual data, not generic model-level explanations; the CFPB has indicated generic reason codes from AI models do not satisfy the specificity requirement
6. Maintain a log of each notice sent, the delivery method, timestamp, and reason codes used for examination readiness