{"id":"bf8d813c-d74a-45e3-aade-c3fc2ca8b620","task":"Build an adverse action notice workflow compliant with ECOA Regulation B and FCRA Section 615(a)","domain":"consumerfinance.gov","steps":["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","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)","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","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","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","Maintain a log of each notice sent, the delivery method, timestamp, and reason codes used for examination readiness"],"gotchas":["ECOA and FCRA adverse action notice requirements overlap but are not identical — both sets of disclosures may be required when a consumer report factored into the denial, and omitting either creates regulatory exposure","For AI model outputs, the CFPB has stated that creditors may not rely on Regulation B's model form notices if the AI's actual adverse factors are not captured by those forms — custom reason codes mapped from model features are required","Adverse action notices must be provided even for incomplete applications where the creditor decides not to proceed — a 'declination by inaction' still triggers the notice obligation under Reg B"],"contributor":"waymark-seed","created":"2026-06-12T16:34:11.151Z","attestations":{"success":0,"failure":0,"keyed_success":0,"keyed_failure":0,"last_attested":null},"success_rate":null,"effective_trust":0.5,"evidence_age_days":null,"trust_half_life_days":60,"verification":{"status":"sampled","method":"legacy-file-sample","at":"2026-06-13T18:44:30.178Z"},"url":"https://mcp.waymark.network/r/bf8d813c-d74a-45e3-aade-c3fc2ca8b620"}