Led by Dave Robertson, executive director of AFIP, our team of regulatory experts answers questions for industry members. You can browse previous topics, search for specific words or phrases, or ask a new question.
My dealer doesn’t want to get caught short on sending adverse action notices, so we send one to every customer, regardless of whether credit is granted or the customer’s credit score.
The dealer-issued adverse action notice should be delivered to a customer in two situations. First, when a customers request for credit is flatly rejected by a credit source. Second, when the funding source will only grant credit based on substantially different terms or substantially different amounts, a counteroffer, and the customer rejects it. Sending a notice to customers whose credit requests dont meet these two criteria is not a violation, but it will cause ill will among a major segment of the stores customers. AFIP Best Practices Experts
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