adverse action notice
What It Means
An adverse action notice is a formal letter that lenders must send to consumers when they deny credit, reduce credit limits, or change loan terms unfavorably. It's essentially a 'rejection letter' that explains why someone didn't get the credit they wanted and informs them of their rights to know the reasons behind the decision.
Why Chief AI Officers Care
AI systems used in lending decisions trigger adverse action notice requirements whenever they recommend denying or limiting credit to applicants. CAIOs must ensure their AI models can generate clear, compliant explanations for credit decisions since these explanations become legally required disclosures. Failure to properly handle adverse action notices can result in significant regulatory penalties and discrimination lawsuits.
Real-World Example
A bank's AI credit scoring system denies a mortgage application and determines the top reasons were 'insufficient income relative to debt obligations' and 'limited credit history length.' The bank must send an adverse action notice within 30 days listing these specific reasons, the applicant's credit score, and information about how to get their free credit report to review the data used in the decision.
Common Confusion
People often think adverse action notices are only required for complete credit denials, but they're also mandatory when AI systems recommend offering different terms than requested, like a lower credit limit or higher interest rate than applied for.
Industry-Specific Applications
See how this term applies to healthcare, finance, manufacturing, government, tech, and insurance.
Healthcare: In healthcare, adverse action notices are required when healthcare organizations deny employment, credentialing, or prof...
Finance: In finance, adverse action notices are mandated by the Fair Credit Reporting Act (FCRA) and Equal Credit Opportunity Act...
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Technical Definitions
NISTNational Institute of Standards and Technology
"A notification of i) a refusal to grant credit in substantially the amount or on substantially the terms requested in an application unless the creditor makes a counteroffer (to grant credit in a different amount or on other terms) and the applicant uses or expressly accepts the credit offered; ii) A termination of an account or an unfavorable change in the terms of an account that does not affect all or substantially all of a class of the creditor's accounts or iii) A refusal to increase the amount of credit available to an applicant who has made an application for an increase."Source: ECOA
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