[LoanMe]

So what exactly do you disclose when giving adverse action notices? The Equal Credit Opportunity Act requires specific reasons for denial and in official staff interpretations, they go into detail as to what needs to be disclosed when using credit scoring systems:

What is disclose in an adverse action letter is between the borrower and the lender. If you have ever seen an adverse action letter, you know it shows a few comments from information gathered by the credit reporting agencies where credit was pulled.

LoanMe has over 150 loan agents taking an average of 15-20 applications per day. Internal scoring and the algorithm used to assess a pre-qualification decline are not something that agents are given access to. This is done for the privacy and protection of the borrower applying for a LoanMe loan.

[jfranz17]

What is disclose in an adverse action letter is between the borrower and the lender. If you have ever seen an adverse action letter, you know it shows a few comments from information gathered by the credit reporting agencies where credit was pulled.

LoanMe has over 150 loan agents taking an average of 15-20 applications per day. Internal scoring and the algorithm used to assess a pre-qualification decline are not something that agents are given access to. This is done for the privacy and protection of the borrower applying for a LoanMe loan.

You are referring to an FCRA Adverse Action, which only must be provided to a consumer applicant. They are not required for business credit because the commercial entity is the applicant, the consumer is a guarantor and does not meet the definition of an applicant.

An ECOA or Reg B adverse action notice is required for business credit and the notice must contain "either a statement of the specific reasons for the action taken or a disclosure of the applicant’s right to a statement of specific reasons and the name, address, and telephone number of the person or office from which this information can be obtained"

[LoanMe]

Privacy is of the utmost concern for LoanMe on both consumer and business information. I'm not sure you understand how our lead referral and application process (initial pre-qual, initial declines, UW declines, etc.) works, and how we are able to abide by the laws for consumer and business loans. If you would like to give us a call directly we would be more than happy to discuss them with you. We can be reached at any of the numbers listed in our signature below.

[jfranz17]

Privacy is of the utmost concern for LoanMe on both consumer and business information. I'm not sure you understand how our lead referral and application process (initial pre-qual, initial declines, UW declines, etc.) works, and how we are able to abide by the laws for consumer and business loans. If you would like to give us a call directly we would be more than happy to discuss them with you. We can be reached at any of the numbers listed in our signature below.

If you and your legal counsel are confident in your compliance program, that's great and I'm sure you are providing adverse action notices directly to your merchants as required by the ECOA.

[FUNd]

I have not faced adverse action from you nor am I your regulator so I'm not particularly interested going into this any further than this discussion.

Really? You seem like you have a serious bone to pick and have sure done a lot of typing for someone who isn't "particularly interested".

[jfranz17]

Yes