FIND THE EXPLANATION
Map the business borrower, collateral, guarantees, and cash commitments before refinancing or requesting a workout.
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Research access date: October 27, 2026, America/Los_Angeles. The final time check was October 28, 2026, 00:28:49 UTC, corresponding to October 27 locally.
Principal finding: Business-purpose credit is within ECOA/Regulation B’s coverage, subject to the instrument’s definitions and specific exceptions. For notifications, the important business classification is ordinarily gross revenues in the business’s preceding fiscal year, with separate treatment for trade credit, credit incident to factoring, and similar business credit. These classifications change notification procedures; they do not establish credit entitlement, underwriting eligibility, or a discrimination finding. Consumer Financial Protection Bureau+2
This is a bounded public-law investigation. It contains no actual applicant, creditor, guarantor, application, revenue, notice, request, receipt, account, or deadline determination. No other research conversation or unreviewed report was used as a foundation. No subagents, party searches, applications, contacts, filings, or publication actions were used. The actual UI model selection and reasoning tier were not independently observable, and no model-switching claim is made.
The current eCFR presentation of §1002.9 displayed Title 12 as updated through October 26, 2026. Other retrieved section snapshots displayed October 22 or October 23 currency dates. Those are compilation-status statements, not proof that each section was amended on those dates. The Office of the Law Revision Counsel’s retrieved versions of 15 U.S.C. §§1691, 1691a, 1691b, and 1691d stated that they contained laws in effect through Public Law 119-134, October 20, 2026. ecfr.gov+6
CFPB’s Regulation B landing page disclosed that updated regulatory text was still forthcoming following two 2026 final rules. I therefore checked the relevant eCFR text and the final rules’ amendment instructions rather than treating the landing page’s “current” label as sufficient. The April 22 rule became effective July 21, 2026; the May 1 rule became effective June 30, 2026, with its stated section 1071 compliance date of January 1, 2028. Neither rule’s amendment instructions replaced §1002.9. The May rule also expressly preserved the separation between its reporting rules and ECOA §701(d)/§1002.9. Consumer Financial Protection Bureau+5
Status distinctions maintained:
| Status | Treatment in this investigation |
|---|---|
| Current codified provisions | Used within the retrieved compilation dates and the clause-specific bounds below. |
| Final rules with effective dates already reached | Checked for changes affecting this component. |
| Future compliance obligations | The May 2026 rule’s section 1071 compliance date was identified only to prevent importing it into current §1002.9 notices. |
| Historical materials | Identified explicitly; not silently substituted for current regulatory text. |
| Proposed provisions | Not treated as operative law. |
| Withdrawn/reference-only guidance | The retrieved October 2015 CFPB examination PDF carried a reference-only notice; it was excluded as a current-law foundation. |
| Stayed, vacated, or later judicially limited provisions | No comprehensive later-history or litigation-status conclusion is made. No case-record or docket query was performed. |
| Unknown | Actual transaction classifications, applicable state exemptions, any post-compilation amendment not reflected in the retrieved bodies, and transaction-specific legal consequences remain unknown. |
This is not a complete session-law, amendment-history, or case-history audit. No CFPB circular, bulletin, or advisory opinion is relied on.
Common metadata: All sources below were accessed October 27, 2026, America/Los_Angeles. Jurisdiction is United States federal law unless expressly described otherwise. HTML has no printed page or PDF index. PDF indices are zero-based. No PDF pixels were inspected; PDF references below describe parsed text only.
| Source ID | Issuer/title and complete literal HTTPS URL | Exact material read and relied-on bounds | Version, effectiveness, status, and limits |
|---|---|---|---|
| R027-P1-S001 | U.S. House, Office of the Law Revision Counsel — 15 U.S.C. §1691, Scope of prohibition. https://uscode.house.gov/us/usc/119-134/t15/s1691/ | Operative subsections (a)–(d) read completely, especially (d)(1)–(6). Subsection (e) and editorial/effective-date notes also appeared and were read for boundary identification; appraisal obligations are excluded from substantive coverage. | Compilation through P.L. 119-134, Oct. 20, 2026. Statute, not agency guidance. No comprehensive session-law or judicial audit. uscode.house.gov |
| R027-P1-S002 | OLRC — 15 U.S.C. §1691a, Definitions; rules of construction. https://uscode.house.gov/us/usc/119-134/t15/s1691a/ | (a)–(g) completely, including applicant, credit, creditor, person, and incorporation of regulations. | Same Oct. 20, 2026 compilation predicate. Statutory definitions are distinguished from Regulation B’s definitions. uscode.house.gov |
| R027-P1-S003 | OLRC — 15 U.S.C. §1691b, Promulgation of regulations by the Bureau. https://uscode.house.gov/us/usc/119-134/t15/s1691b/ | (a)–(g) completely. Material provisions: classification/exception authority (a)–(c); records (d); business-loan denial notice (e); reserved Board authority (f). | Same Oct. 20 compilation. Subsection (g) was read but no judicial-deference conclusion is made. Full recordkeeping and remedies remain held. uscode.house.gov |
| R027-P1-S004 | OLRC — 15 U.S.C. §1691d, Applicability of other laws. https://uscode.house.gov/us/usc/119-134/t15/s1691d/ | (a)–(g) completely. Reliance here is principally on (f)–(g). Signature, marital-property, finance-charge aggregation, and remedy provisions were read to preserve boundaries, not applied. | Same Oct. 20 compilation. Earlier Oct. 7 snapshot was superseded for this report by successful retrieval of this version. uscode.house.gov |
| R027-P1-S021 | OLRC — 12 U.S.C. §5519, Exclusion for auto dealers. https://uscode.house.gov/us/usc/119-124/t12/s5519/ | (a)–(f) completely; necessary cross-reference for §1002.1(a), including the exclusion, functional exceptions, preserved authority, and statutory definitions. | Retrieved compilation through P.L. 119-124, Oct. 15, 2026. No actual dealer classification, license search, vehicle classification, or complete Part 202 investigation. The later compilation interval remains a source limit. uscode.house.gov |
| Source ID | Issuer/title and complete literal HTTPS URLs | Exact material read and relied-on bounds | Version/status and limits |
|---|---|---|---|
| R027-P1-S005 | CFPB/OFR-GPO — §1002.1, Authority, scope and purpose, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.1; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-1/ | Entire (a)–(b); comments 1(a)-1 through -3. | eCFR snapshot through Oct. 23, 2026. Official interpretation distinguished from statutory text. Geographic discussion concerns federal applicability only. ecfr.gov+1 |
| R027-P1-S006 | §1002.2, Definitions, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.2; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-2/ | Regulatory definitions read, with reliance on (a), (c), (e)–(j), (l)–(m), (q), (s), (w), (x), (z), (aa). Complete relevant comments: 2(c)(1)(i)-1; 2(c)(1)(ii)-1–2; 2(c)(2)(ii)-1–2; 2(c)(2)(iii)-1–2; 2(c)(2)(v)-1; 2(e)-1; 2(f)-1–6; 2(g)-1; 2(j)-1; 2(l)-1–2. | eCFR through Oct. 26, 2026. The separate scoring-validity and discrimination-merits investigation is held. The April 2026 changes to comment 2(p) are not imported into this notice analysis. ecfr.gov+4 |
| R027-P1-S007 | §1002.3, Limited exceptions, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.3; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-3/ | Entire (a)–(d), including definitions and exception lists; all displayed substantive comments: 3-1; 3(a)-1–3; 3(c)-1; 3(d)-1. | eCFR through Oct. 26, 2026. Narrow Regulation Z cross-reference identified; no independent finance-charge calculation or securities-law analysis. ecfr.gov+1 |
| R027-P1-S008 | §1002.9, Notifications, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.9; https://www.consumerfinance.gov/rules-policy/regulations/1002/9/; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-9/ | Entire (a)–(g). Complete comments 9-1–5; 9(a)(1)-1–7; 9(a)(3)-1–5; 9(b)(1)-1; 9(b)(2)-1–9; 9(c)(1)-1; 9(c)(2)-1; 9(c)(3)-1; 9(g)-1–3, including examples. | eCFR through Oct. 26, 2026. Section’s amendment note identifies the 2023 technical amendment; S018 verifies its effective date and scope. No actual notice or request was reviewed. ecfr.gov+3 |
| R027-P1-S009 | §1002.4, General rules. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.4 | (a), (c)–(e); current (b) was visible but its merits are held. Material reliance: written applications, clear/conspicuous and retainable disclosures, electronic-form cross-reference, language. | eCFR through Oct. 26, 2026; incorporates April 2026 amendment effective July 21. No full E-Sign compliance analysis. ecfr.gov |
| R027-P1-S010 | §1002.12, Record retention, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.12; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-12/ | Complete (b)(1)–(5); comments 12(b)-1–2 and 12(b)(3)-1. Other displayed provisions were not developed into a full recordkeeping investigation. | Snapshot through Oct. 23, 2026. Express Subpart B qualifications preserved. No destruction authorization or complete privacy/retention schedule. ecfr.gov+1 |
| R027-P1-S011 | §1002.13, Information for monitoring purposes, and interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.13; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-13/ | Regulatory (a)–(d) read; relevant comments 13(a)-1–5 read. Used only for the monitoring/application-form boundary. | Retrieved snapshot through Oct. 22, 2026. No protected-characteristic data obtained; no HMDA or section 1071 investigation. ecfr.gov+1 |
| R027-P1-S012 | Appendix C, Sample Notification Forms. https://www.consumerfinance.gov/rules-policy/regulations/1002/c/; https://www.ecfr.gov/current/title-12/chapter-X/part-1002/appendix-Appendix%20C%20to%20Part%201002 | Introductory paragraphs 1–5; complete HTML text of C-4, C-5, C-6, C-7, C-8. CFPB parsed bounds: C-4 lines 293–330; C-5 331–379; C-6 380–394; C-7 395–409; C-8 410–417. | Current online codified samples, latest checked eCFR snapshot through Oct. 26, 2026. Appendix amendment note: 2011 and 2013; not a newly revised “2026 form.” No form PDF or pixels inspected. C-1–C-3 were identified by the introduction, not fully audited. Consumer Financial Protection Bureau+4 |
| R027-P1-S013 | Appendix A, Federal Agencies To Be Listed in Adverse Action Notices. https://www.consumerfinance.gov/rules-policy/regulations/1002/a/ | Introductory scope and displayed initial classifications, particularly the statement that the list identifies notice agencies and is not a description of all enforcement authority. | Current online text, with 2023 amendment timing verified in S018. No agency was selected for an actual creditor; no creditor roster consulted. Consumer Financial Protection Bureau |
| R027-P1-S014 | §1002.11, Relation to state law. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.11 | (a)–(e) read; reliance limited principally to (a), (e) and preservation boundaries. | Snapshot through Oct. 23, 2026. No state-law survey, state exemption determination, or remedy assessment. ecfr.gov |
| R027-P1-S015 | §1002.16(c), Failure of compliance, and interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.16; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-16/ | Complete (c) and comments 16(c)-1–2, with §1002.2(s). Other enforcement/remedy text was not applied. | eCFR through Oct. 23, 2026. Narrow error exception only; no actual liability determination. ecfr.gov+1 |
| Source ID | Issuer/title and complete literal HTTPS URLs | Exact read bounds | Status and limits |
|---|---|---|---|
| R027-P1-S016 | CFPB — Equal Credit Opportunity Act (Regulation B), April 22, 2026, 91 FR 21620. https://www.federalregister.gov/documents/2026/04/22/2026-07804/equal-credit-opportunity-act-regulation-b; https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07804.pdf | Dates/summary; amendment instructions 1–6, printed 21668–21669; narrow current comment 8(b)-1, printed 21670. PDF parsed excerpts at index 0, 48–49; corresponding operative HTML read. | Final; effective July 21, 2026. Changes §1002.4(b), §1002.6(a), specified §1002.8/§1002.15 provisions and interpretations; no §1002.9 amendment in these instructions. Full merits/preamble and judicial history excluded. govinfo.gov+3 |
| R027-P1-S017 | CFPB — Small Business Lending Under ECOA, May 1, 2026, 91 FR 23530. https://www.federalregister.gov/documents/2026/05/01/2026-08494/small-business-lending-under-the-equal-credit-opportunity-act-regulation-b; https://www.govinfo.gov/content/pkg/FR-2026-05-01/pdf/2026-08494.pdf | Dates/summary; complete amendment-direction sequence 1–13, printed 23604–23609; narrow comment 109(a)(3)-1.i preserving §701(d)/§1002.9. PDF parsed excerpts: index 0, 74–75, 78–79; other direction text read in HTML. | Final; effective June 30, 2026; stated compliance date Jan. 1, 2028. Subpart B investigation remains held. No §1002.9 amendment in the directions. No full 97-page read or pixel claim. govinfo.gov+3 |
| R027-P1-S018 | CFPB — Agency Contact Information, March 20, 2023, 88 FR 16531. https://www.federalregister.gov/documents/2023/03/20/2023-05216/agency-contact-information; https://www.govinfo.gov/content/pkg/FR-2023-03-20/pdf/2023-05216.pdf | Dates at printed 16531, PDF index 0; HTML section IV.A and amendment instructions 3–4, printed 16537, concerning §1002.9(b)(1) and Appendix A. | Final technical rule; effective Apr. 19, 2023; Appendix A mandatory compliance Mar. 20, 2024. Other regulations in this rule excluded. federalregister.gov+2 |
| R027-P1-S019 | Federal Reserve Board — Background and Summary of Regulation B, Federal Reserve Regulatory Service. https://www.federalreserve.gov/frrs/regulations/background-and-summary-of-regulation-b.htm | Business-credit discussion 6-142.2–6-142.4, especially “Applicants with Revenues of More than $1 Million.” HTML lines 3815–3831. | Agency explanatory summary using Part 202 numbering, not the current Part 1002 regulation or a statute. Edition date not established. Used narrowly to corroborate the receipt-based 30-day reasons-response reading of §1691(d)(2)(B), not to replace current law. federalreserve.gov |
| R027-P1-S020 | CFPB — 12 CFR Part 1002 landing page. https://www.consumerfinance.gov/rules-policy/regulations/1002/ | Currentness notices, links to the two 2026 final rules, and legal-edition disclaimer. | Publisher status/context only. Its “most recently amended July 21, 2026” statement is not a complete amendment or judicial-history audit. Consumer Financial Protection Bureau |
| R027-P1-S022 | CFPB — October 2015 ECOA narrative and examination procedures. https://files.consumerfinance.gov/f/201510_cfpb_ecoa-narrative-and-procedures.pdf | Parsed cover, PDF index 0; narrow examination question 46, printed Procedures 23, PDF index 36. | Historical/reference-only. Cover explains that related bulletin material has no force or effect. Not used as a current-law foundation; no full-document or pixel inspection claim. files.consumerfinance.gov+1 |
Unless a row states otherwise, notification rules below assume a covered credit transaction and a creditor subject to the relevant provision. The §1002.3 exceptions, §1002.9(d) small-volume alternative, and other stated conditions must be checked before applying a particular notice format.
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C001 | ECOA addresses discrimination in any aspect of a credit transaction, and Regulation B reaches commercial as well as personal credit. Coverage establishes regulatory duties; the notification provisions do not themselves promise that an application will be approved. | S001 §1691(a), (d); S005 §1002.1(a)–(b), comment 1(a)-1. uscode.house.gov+1 |
| R027-P1-C002 | Statutory “applicant” includes a person applying directly for an extension, renewal, or continuation, and specified indirect applications exceeding an existing limit. Statutory “credit” concerns a right to defer payment. “Person” includes natural persons and the listed organizational/governmental forms. Statutory “creditor” includes regular extenders, arrangers, and participating assignees. | S002 §1691a(b), (d)–(f). uscode.house.gov |
| R027-P1-C003 | For Regulation B, a creditor ordinarily regularly participates in credit decisions, including setting terms; participating assignees, transferees, and subrogees are included. The additional inclusion of referral/selection intermediaries is expressly for §1002.4(a)–(b). Mere referral status should not automatically be converted into a §1002.9 notice obligation. | S006 §1002.2(l), comments 2(l)-1–2. ecfr.gov+1 |
| R027-P1-C004 | Regulation B’s applicant definition covers a person requesting or receiving credit and persons who are or may become contractually liable. Its express inclusion of guarantors, sureties, endorsers, and similar parties is stated for §1002.7(d). This report makes no independent guarantor-notice or signature ruling. | S006 §1002.2(e), (i). ecfr.gov |
| R027-P1-C005 | An application is an oral or written credit request made under the creditor’s procedures for that credit type. “Procedures” includes actual practices, not merely a stated written-form policy. A creditor that actually decides oral requests cannot disregard that practice solely because its policy calls for a form. | S006 §1002.2(f), comments 2(f)-1–2. ecfr.gov+1 |
| R027-P1-C006 | Completion turns on the creditor having received all information it regularly obtains and considers for the requested amount/type, including necessary third-party reports or guarantee/security approvals. The creditor must exercise reasonable diligence in obtaining it. Submission of an applicant’s form alone does not necessarily establish completion; creditor delay does not erase the diligence duty. | S006 §1002.2(f), comment 2(f)-6; S008 comment 9(a)(1)-1. ecfr.gov+2 |
| R027-P1-C007 | Use of an account or credit line within an established limit is excluded from the application definition. A procedurally valid application to increase available credit is different; refusal of that request may be adverse action. | S006 §1002.2(f), (c)(1)(iii), comment 2(c)(2)(iii)-2. ecfr.gov+1 |
| R027-P1-C008 | Business credit is primarily for business/commercial purposes, including agriculture, excluding the classes in §1002.3(a)–(d). Consumer credit is credit to a natural person primarily for personal, family, or household purposes. Mixed use requires a primary-purpose determination; the creditor may rely on the applicant’s purpose statement. | S006 §1002.2(g)–(h), comment 2(g)-1. ecfr.gov+1 |
| R027-P1-C009 | The official inquiry/prequalification examples distinguish discussion of general terms from evaluating information, deciding to reject, and communicating that decision. The creditor’s response matters; calling the exchange an “inquiry” does not control its legal classification. The published examples are consumer examples, not an actual business-credit finding. | S006 comments 2(f)-3–4; S008 comment 9-5. Consumer Financial Protection Bureau+1 |
| R027-P1-C010 | The official preapproval example involves comprehensive creditworthiness review and a written commitment for a designated period, subject only to the specified collateral, no-material-change, and limited ordinary conditions. Denial under that program is also an application disposition. A program without written commitments is treated as prequalification under the comment. | S006 comment 2(f)-5(i)–(ii). Consumer Financial Protection Bureau |
| R027-P1-C011 | Regulatory adverse action includes refusal of substantially the amount/terms requested, subject to an accepted-or-used counteroffer; termination or an unfavorable account change not affecting all/substantially all of a class; and refusal of an applied-for increase. | S006 §1002.2(c)(1)(i)–(iii); S001 §1691(d)(6). ecfr.gov+1 |
| R027-P1-C012 | Exclusions include expressly agreed account changes; action connected with inactivity/default/delinquency on that account; specified point-of-sale/loan authorization refusals; credit prohibited by applicable law; and a credit type/plan the creditor does not offer. The stated point-of-sale exceptions must also be checked. If both inclusion and exclusion apply, §1002.2(c)(2) governs. | S006 §1002.2(c)(2)–(3). ecfr.gov |
| R027-P1-C013 | Refusing requested terms of an offered credit type is different from not offering that type of credit. Denial because of requested rate, maturity, collateral, or down payment is adverse action unless an applicable counteroffer exception applies. Refusal to refinance or extend a business loan’s term is adverse action when the applicant followed the creditor’s application procedures. | S006 comments 2(c)(2)(v)-1 and 2(c)(1)(i)-1. Consumer Financial Protection Bureau+1 |
| R027-P1-C014 | The account-default exception concerns current default or delinquency on that account. The interpretation says notification generally is required when action is based on a past delinquency/default. Neither historical payment trouble nor default on some unidentified account establishes the exception. | S006 §1002.2(c)(2)(ii), comment 2(c)(2)(ii)-2. ecfr.gov+1 |
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C015 | Qualifying public-utilities credit requires the specified utility-service delivery and governmental filing/regulation of charges. Its listed exceptions concern marital-status information and record retention; §1002.9 is not among them. Utility financing of equipment or other goods is not automatically within the utility-service exception. | S007 §1002.3(a)(1)–(2), comments 3(a)-1–3. ecfr.gov+1 |
| R027-P1-C016 | Securities credit has a specific statutory/regulatory classification and a list of exceptions. That list does not except §1002.9. Its exclusion from the definition of “business credit” must not be mistaken for exclusion from all Regulation B procedures. | S007 §1002.3(b); S006 §1002.2(g). ecfr.gov+1 |
| R027-P1-C017 | Incidental credit under §1002.3(c) is consumer credit, outside the utility/securities categories, not under a credit-card account, without a Regulation Z finance charge, and not contractually payable in more than four installments. Qualifying incidental credit is excepted from §1002.9. These conditions cannot simply be transferred to business trade credit. | S007 §1002.3(c)(1)–(2), comment 3(c)-1. ecfr.gov+1 |
| R027-P1-C018 | “Government credit” means credit to governments and their listed subdivisions/agencies/instrumentalities. Except for §1002.4(a), the regulation’s requirements do not apply to that class. Credit by a government agency does not qualify merely because of the creditor’s governmental status. | S007 §1002.3(d), comment 3(d)-1. ecfr.gov+1 |
| R027-P1-C019 | Part 1002 excludes persons covered by the §1029/§5519 dealer exclusion, with statutory functional exceptions. Section 5519(b) preserves specified mortgage/real-property services, certain direct retail-credit/leasing businesses whose contracts are not routinely assigned to unaffiliated finance sources, and unrelated consumer financial products. This is not an exemption from ECOA itself; §1691b(f) preserves Board rulemaking. | S005 §1002.1(a), comment 1(a)-1; S021 §5519(a)–(c), (f); S003 §1691b(f). No actual dealer classification. Consumer Financial Protection Bureau+2 |
| R027-P1-C020 | Section 1691b grants classification, differentiation, adjustment, and exception authority. Subsections (b)–(c) address exemption findings and duration, including a five-year limit and a subsequent determination for extension. They do not themselves establish that an unidentified business transaction has a blanket exemption. | S003 §1691b(a)–(c); actual regulatory classes in S007–S008. uscode.house.gov |
| R027-P1-C021 | Section 1691b(d) directs business/commercial lenders to maintain compliance-related records under regulations and states a minimum one-year period for the records/data it addresses. The application-specific regulation separately contains §1002.12(b)(5). This report preserves both texts and does not turn the special application rule into universal authorization to discard all business-loan records after 60 days. | S003 §1691b(d); S010 §1002.12(b)(1)–(5). uscode.house.gov+1 |
| R027-P1-C022 | Section 1691b(e) directs the Bureau to provide by regulation written notice of a business/commercial loan applicant’s right to a written denial-reasons statement. The actual procedural implementation must be read with §1002.9’s alternatives and exceptions, including the entirely-telephone and small-volume provisions. | S003 §1691b(e); S008 §1002.9(a)(3), (d). uscode.house.gov+1 |
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C023 | Section 1002.9(a)(3)(i) addresses a business with gross revenues of $1 million or less in its preceding fiscal year, excluding trade credit, credit incident to factoring, and similar business credit. Subparagraph (ii) addresses revenues over $1 million, or those listed credit categories. This is a revenue-and-period test, not a loan-amount, limit, balance, collateral, or net-profit test. | S008 §1002.9(a)(3)(i)–(ii). ecfr.gov |
| R027-P1-C024 | The creditor may rely on the applicant’s revenue assertion. Comment 9(a)(3)-1 directs startup applications to (i); sole-proprietor applications use the proprietorship’s revenues; an individual applying for business credit uses (i) unless trade/similar credit. Product exceptions still require separate classification. | S008 comment 9(a)(3)-1. Consumer Financial Protection Bureau |
| R027-P1-C025 | Trade credit generally means buyer–seller financing, such as a supplier financing its sale of equipment, supplies, or inventory. A bank or other financial institution financing those same items is not thereby extending “trade credit” under this interpretation. | S008 comment 9(a)(3)-2. Consumer Financial Protection Bureau |
| R027-P1-C026 | The interpretation describes factoring as a purchase of receivables and therefore outside the Act/regulation. A credit extension incident to factoring is different: §1002.9(a)(3)(ii) and other relevant provisions apply. A product label alone does not establish which transaction occurred. | S008 comment 9(a)(3)-3; S006 §1002.2(j). Consumer Financial Protection Bureau+1 |
| R027-P1-C027 | A business-credit creditor may elect to follow the consumer notification rules. It may also treat all business credit under §1002.9(a)(3)(i), irrespective of revenue size. Those are permitted compliance routes; the special route is not compulsory merely because the applicant exceeds the threshold. | S008 comment 9(a)(3)-4. Consumer Financial Protection Bureau |
| R027-P1-C028 | Under §1002.9(a)(1)(i), notice of approval, counteroffer, or adverse action is due within 30 days after the creditor receives a completed application. The smaller-business route incorporates this timing. The larger/trade route has the reasonable-time alternative described in C038. | S008 §1002.9(a)(1)(i), (a)(3)(i), comment 9(a)(1)-1. ecfr.gov+1 |
| R027-P1-C029 | Section 1002.9(a)(1)(ii) measures 30 days from taking adverse action on an incomplete application, unless the paragraph (c) route is used. Paragraph (c)(1) independently addresses the initial receipt of an applicant-completable incomplete application; the two provisions cannot be stacked into an assumed extra waiting period. | S008 §1002.9(a)(1)(ii), (c)(1); see C043. ecfr.gov |
| R027-P1-C030 | The standard existing-account notice period is 30 days after taking adverse action. First determine that the action is adverse action under §1002.2(c), including its current-default, agreed-change, and other exclusions. | S008 §1002.9(a)(1)(iii); S006 §1002.2(c). ecfr.gov+1 |
| R027-P1-C031 | The standard counteroffer provision requires adverse-action notification within 90 days after notifying the applicant of the counteroffer when the applicant neither expressly accepts nor uses it. This provision does not require keeping the offer open for 90 days. A compliant combined notice can eliminate a second notice. | S008 §1002.9(a)(1)(iv), comments 9(a)(1)-5–6. ecfr.gov+1 |
| R027-P1-C032 | The ordinary adverse-action notice is written and includes the action, creditor’s name/address, the ECOA statement, the responsible federal agency’s name/address, and either specific reasons or the prescribed right-to-request disclosure. Business and small-volume alternatives qualify this ordinary format. | S008 §1002.9(a)(2), (b)(1), (a)(3), (d). ecfr.gov |
| R027-P1-C033 | Under the ordinary right-to-request route, a request made within 60 days of notification invokes a reasons statement within 30 days after the creditor receives the request. The disclosure identifies the person/office and its address/telephone number. Making the request and the creditor receiving it are distinct events. | S001 §1691(d)(2)(B); S008 §1002.9(a)(2)(ii); S012 C-5/C-8. uscode.house.gov+2 |
| R027-P1-C034 | Where reasons are provided orally under the ordinary route, the applicant must also be told of the right to written confirmation within 30 days after the creditor receives the applicant’s written confirmation request. This is a separate request/response mechanism. The special written-response route and §1002.9(d) must be checked separately. | S008 §1002.9(a)(2)(ii); S001 §1691(d)(2)(B), (5). ecfr.gov+1 |
| R027-P1-C035 | For the smaller-business route, the statement of action taken may be oral or written. That permission does not by itself convert every other required component into an oral disclosure. Paragraphs (a)(1)–(2) otherwise apply subject to the specified exceptions. | S008 §1002.9(a)(3)(i)(A). ecfr.gov |
| R027-P1-C036 | The smaller-business creditor may give the right-to-reasons disclosure at application, instead of at adverse action, if it contains the §1002.9(a)(2)(ii) information and the §1002.9(b)(1) ECOA notice. This is optional and does not itself communicate the later credit decision. | S008 §1002.9(a)(3)(i)(B); S012 C-8. ecfr.gov+1 |
| R027-P1-C037 | For a smaller-business application made entirely by telephone, an oral statement of action and the right to reasons satisfies §1002.9(a)(3)(i). The general telephone-denial comment otherwise calls for obtaining an address to send a required written notice; its rule must not erase this express business exception. | S008 §1002.9(a)(3)(i)(C), comment 9(a)(1)-7. ecfr.gov+1 |
| R027-P1-C038 | For larger businesses and the trade/factoring/similar categories, action may be communicated orally or in writing within a reasonable time. Comment 9(a)(3)-5 identifies receipt of the completed application as the application-action trigger and deems timing compliant with §1002.9(a)(1) reasonable in all instances. “Reasonable” is not an unlimited waiting period. | S008 §1002.9(a)(3)(ii)(A), comment 9(a)(3)-5. ecfr.gov+1 |
| R027-P1-C039 | Under the larger/trade route, a written request within 60 days of notification requires written adverse-action reasons and the ECOA notice, subject to another applicable express exception. Subparagraph (ii)(B) does not separately restate a response interval. The receipt-based 30-day response is grounded in §1691(d)(2)(B); the Federal Reserve’s explanatory summary expressly applies it to larger businesses. | S008 §1002.9(a)(3)(ii)(B); S001 §1691(d)(2)(B); S019 6-142.3. The summary is supplementary agency explanation, not substituted statutory text. ecfr.gov+2 |
| R027-P1-C040 | A creditor that received no more than 150 applications in the preceding calendar year may satisfy §1002.9, including reasons statements, through oral notifications. The statute uses “did not act on more than” 150 and directs regulatory implementation. The operative regulatory count is received applications, not approved loans, business revenue, or the applicant’s fiscal year. | S008 §1002.9(d); S001 §1691(d)(5). Timing/content duties are not erased merely because oral delivery is permitted. ecfr.gov+1 |
| R027-P1-C041 | The interpretation places notification at delivery or mailing to the applicant’s last known address, or at communication of an oral decision. That is different from the creditor’s later receipt of a reasons request, which starts the response period. No mailbox, holiday, or electronic-delivery convention is inferred here. | S008 comment 9-3; S001 §1691(d)(2)(B). Consumer Financial Protection Bureau+1 |
| R027-P1-C042 | Approval notice can be express or implied; the interpretation gives provision of the requested card, money, property, or services as examples. Approval does not automatically require the adverse-action reasons package. | S008 comment 9(a)(1)-2. Consumer Financial Protection Bureau |
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C043 | Within 30 days after receipt of an application incomplete as to matters the applicant can complete, §1002.9(c)(1) requires either action notice under paragraph (a) or an incompleteness notice under (c)(2). The incompleteness-notice route is optional; doing nothing is not a third alternative supplied by this clause. The preapproval and other express exceptions remain relevant. | S008 §1002.9(c)(1), comment 9(c)(1)-1. The special reasonable-time rule for completed business applications does not itself delete paragraph (c). ecfr.gov+1 |
| R027-P1-C044 | A paragraph (c)(2) notice specifies the needed information, gives a reasonable period to supply it, and explains that failure will end further consideration. The ordinary route is written; §1002.9(d) is a separate oral-notification exception when its predicate is established. | S008 §1002.9(c)(2), (d); S012 C-6. ecfr.gov+1 |
| R027-P1-C045 | Timely supply of the requested information requires action and notice under paragraph (a). Failure to respond within the designated period ends further obligation under §1002.9 under this route. Late submission may be treated as requiring a new application. These are not conclusions about contract, other law, or actual completeness. | S008 §1002.9(c)(2), comment 9(c)(2)-1. ecfr.gov+1 |
| R027-P1-C046 | If applicant-supplied information is missing and there is insufficient information to decide, incompleteness may be the denial reason. If enough information exists to make the adverse decision for another reason, the creditor must give that actual reason or the prescribed right-to-request disclosure; it cannot substitute “incomplete application.” | S008 comments 9(a)(1)-3–4. Consumer Financial Protection Bureau |
| R027-P1-C047 | An oral request for missing information is permitted. If the application remains incomplete, the creditor must provide the notice required by §1002.9(c)(1) within its period; an ordinary oral inquiry is not itself a perpetual substitute for the required notice. | S008 §1002.9(c)(3), comment 9(c)(3)-1. Applicable §1002.9(d) remains separate. ecfr.gov+1 |
| R027-P1-C048 | The official interpretation excepts preapprovals constituting applications under §1002.2(f) from the requirement to provide an incompleteness notice. This is not an exception from all application or adverse-action duties. | S008 comment 9(c)(1)-1; S006 comment 2(f)-5. Consumer Financial Protection Bureau+1 |
| R027-P1-C049 | Express acceptance or use of the counteroffered credit satisfies the counteroffer condition in the adverse-action definition. If a compliant adverse-action notice was combined with the counteroffer, a second adverse-action notice is unnecessary upon nonacceptance. The offer’s expiration and the notification deadline remain separate concepts. | S006 §1002.2(c)(1)(i); S008 comments 9(a)(1)-5–6; S012 C-4. ecfr.gov+2 |
| R027-P1-C050 | An expressly withdrawn application does not require §1002.9 notification, although record-retention obligations remain. Silence or missing information is not automatically an express withdrawal. | S008 comment 9-2; S010 §1002.12(b)(3). Consumer Financial Protection Bureau+1 |
| R027-P1-C051 | The approved-application withdrawal rule is narrow: the parties contemplated that the applicant would inquire about status, the creditor approved, and the applicant did not inquire within 30 days after applying. The creditor may then treat it as withdrawn and need not comply with (a)(1). | S008 §1002.9(e). ecfr.gov |
| R027-P1-C052 | For multiple applicants, one notification is sufficient, but it must go to the primary applicant if one is readily apparent. This provision does not decide who legally counts as an applicant or give a guarantor an independently established notice status. | S008 §1002.9(f); S006 §1002.2(e). ecfr.gov+1 |
| R027-P1-C053 | When an application is submitted on an applicant’s behalf to multiple creditors, the others need not notify if the applicant expressly accepts or uses one creditor’s offered credit. If no offer is made, or none is expressly accepted/used, each creditor taking adverse action must comply directly or through a third party. Mere approval is not the stated acceptance/use predicate. | S008 §1002.9(g); S001 §1691(d)(4). ecfr.gov+1 |
| R027-P1-C054 | A combined third-party notice identifies each creditor, including names/addresses under the interpretation, and either gives the request-right disclosure or clearly attributes each creditor’s principal reasons. Where several federal enforcement agencies are involved, the interpretation permits listing any one of them for that combined notice. | S008 §1002.9(g), comments 9(g)-1–2. Consumer Financial Protection Bureau |
| R027-P1-C055 | The third-party interpretation supplies a conditional protection when the creditor accurately and timely supplies needed notice information and maintains reasonable procedures adapted to prevent violations. Delegation alone is not the condition. No actual liability assessment is made here. | S008 comment 9(g)-3. Consumer Financial Protection Bureau |
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C056 | Reasons must be specific and identify the principal reasons actually supporting the adverse action. A generic reference to internal standards/policies or failure to attain a qualifying creditor score is insufficient. The ECOA nondiscrimination statement is not itself a statement of denial reasons. | S001 §1691(d)(3); S008 §1002.9(b)(1)–(2), comments 9(b)(2)-1–2. uscode.house.gov+2 |
| R027-P1-C057 | In credit scoring, disclosed reasons must correspond to actual scored factors, and a principal adverse factor cannot simply be omitted. The comment does not require explaining the factor’s predictive relationship to creditworthiness. | S008 comments 9(b)(2)-2–4. Consumer Financial Protection Bureau |
| R027-P1-C058 | Judgmental reasons concern factors actually reviewed by the decision-maker. In a combined system, reasons come from the failed component; where the described intermediate-score/judgmental process is used, reasons may need to come from both components. Actual system operation remains unknown. | S008 comments 9(b)(2)-6–7, including all examples. Consumer Financial Protection Bureau |
| R027-P1-C059 | The interpretation does not impose one method for selecting scoring reasons or a fixed required number. Its observation that more than four reasons is unlikely to help is not a four-reason legal cap. An automatic-denial factor must be disclosed when it caused the denial. | S008 comments 9(b)(2)-1, -5, -8. No scoring arithmetic performed. Consumer Financial Protection Bureau |
| R027-P1-C060 | A notice that a consumer report was used, or a list of factors affecting a consumer credit score, does not by itself satisfy ECOA’s requirement to explain the creditor’s actual adverse-action reasons. This is the narrow FCRA cross-reference; actual FCRA coverage and notices remain held. | S008 comment 9(b)(2)-9; S012 Appendix C paragraph 2. Consumer Financial Protection Bureau+1 |
| R027-P1-C061 | Written Regulation B disclosures must be clear/conspicuous and, subject to specified exceptions not including §1002.9, in a retainable form. Required writings may be electronic subject to applicable E-Sign requirements. The special application-accompanying exceptions listed in §1002.4(d)(2) do not list §1002.9. | S009 §1002.4(d)(1)–(2). No actual electronic-delivery compliance finding. ecfr.gov |
| R027-P1-C062 | A creditor must take written applications for the dwelling-related credit covered by §1002.13(a). Disclosures may be in another language if available in English on request. Neither provision creates a mandatory nationwide business-credit application form. | S009 §1002.4(c), (e); S011 §1002.13(a). ecfr.gov+1 |
| R027-P1-C063 | Under §1002.12(b)(1), the ordinary business-credit retention period is 12 months after notification of action or incompleteness, subject to (b)(5) and Subpart B. Covered material includes the application and retained evaluation information, written action/reasons notices or any notation/memorandum made for oral notices, and written allegations of violations. | S010 §1002.12(b)(1)(i)–(iii). The “any notation made” language is not rewritten as a duty to create a verbatim transcript. ecfr.gov |
| R027-P1-C064 | Existing-account records use the notice-of-adverse-action trigger under (b)(2). Applications with no §1002.9 notice duty use the creditor’s receipt-of-application trigger under (b)(3). Both contain business-credit and other qualifications. The ordinary consumer 25-month period must not silently replace the business provision. | S010 §1002.12(b)(2)–(3), comment 12(b)(3)-1. ecfr.gov+1 |
| R027-P1-C065 | For the larger-business/trade/factoring/similar category, (b)(5) requires records for at least 60 days after action notification, except as otherwise provided in Subpart B. A written request within that period for reasons or for retention invokes the provision’s 12-month retention requirement. A retention request is not automatically a reasons request. | S010 §1002.12(b)(5). Full retention duties and any actual destruction date remain held. ecfr.gov |
| R027-P1-C066 | The specified actual-notice/service predicates for investigations or enforcement proceedings extend retention until final disposition unless the agency/court permits earlier release. The ordinary period’s expiration therefore is not universal permission to destroy. | S010 §1002.12(b)(4). No proceeding or docket was queried. ecfr.gov |
| R027-P1-C067 | Section 1002.13’s monitoring collection applies to the defined principal-residence purchase/refinance setting; its interpretation limits it to natural-person applications. A dwelling as collateral alone does not establish that section’s purpose predicate. This is separate from the business-notice revenue classification and section 1071. | S011 §1002.13(a), comments 13(a)-1–5. ecfr.gov+1 |
| R027-P1-C068 | Appendix C permits creditor-designed notices and use of all or parts of the samples. Its compliance statements require proper use. The bounded read establishes optional/illustrative samples for this framework, not a universally mandatory single national notice form. | S012 Appendix C paragraphs 1, 3–5. Consumer Financial Protection Bureau+1 |
| R027-P1-C069 | C-4 illustrates a counteroffer with adverse action/reasons; C-5 the later-request alternative; C-6 incompleteness; C-7 business adverse action/reasons; C-8 the business right-to-reasons disclosure at application. C-8 includes the 60-day request and receipt-based 30-day response language. | S012 Forms C-4 through C-8, bounds in source register. Consumer Financial Protection Bureau+1 |
| R027-P1-C070 | Checking the closest listed reason is inadequate if it was not an actual factor. Appendix C directs modification or an appropriate explanation where necessary; the sample’s vocabulary cannot replace the real principal reason. | S012 paragraphs 3–4; S008 comment 9(b)(2)-2. Consumer Financial Protection Bureau+1 |
| R027-P1-C071 | The ECOA notice must be substantially similar to §1002.9(b)(1) and identify the appropriate federal notice agency under Appendix A. Appendix A does not purport to describe every agency’s enforcement authority. No actual creditor’s agency can be selected from unknown status facts. | S008 §1002.9(b)(1), comment 9(b)(1)-1; S013 introduction. ecfr.gov+2 |
| R027-P1-C072 | Federal law preserves state credit-discrimination protections except for inconsistency; greater protection is not treated as inconsistent under the stated standards. A state-regulated class exemption requires the statutory/regulatory determination and enforcement predicates. No particular state exemption is established here. | S004 §1691d(f)–(g); S014 §1002.11(a), (e). uscode.house.gov+1 |
| R027-P1-C073 | An inadvertent error requires an unintentional mechanical/electronic/clerical error despite reasonably adapted preventive procedures. Section 1002.16(c) addresses specified failures, including §1002.9, and requires notice errors to be corrected as soon as possible after discovery. An error of legal judgment is not the defined inadvertent error. | S006 §1002.2(s); S015 §1002.16(c), comment 16(c)-1. ecfr.gov+2 |
| R027-P1-C074 | A special-purpose-program eligibility denial is not automatically a notice exemption. Current comment 8(b)-1 says that a creditor rejecting an application because program eligibility requirements are unmet must nevertheless notify as §1002.9 requires. Program validity and discrimination merits remain held. | S016 current comment 8(b)-1; S001 §1691(c). federalregister.gov+1 |
| R027-P1-C075 | Source currency is bounded by the retrieved bodies: the four ECOA statutory sections state Oct. 20, 2026 legislative currency, and the principal notification eCFR page states Oct. 26. These statements are not a full later-law or judicial-history audit. | S001–S004; S008; S020. uscode.house.gov+3 |
| R027-P1-C076 | The two examined 2026 final rules have effective dates already reached, but their amendment directions do not replace §1002.9. The April rule also preserves the specific special-purpose denial-notice instruction identified in C074. | S016 Dates; instructions 1–6; S017 Dates; instructions 1–13. govinfo.gov+3 |
| R027-P1-C077 | The 2023 amendment removed an obsolete §1002.9(b)(1) sentence allowing old agency-contact information and revised Appendix A. Its general effective date was Apr. 19, 2023; the Appendix A mandatory compliance date was Mar. 20, 2024. | S018 Dates, IV.A, amendment instructions 3–4. federalregister.gov+1 |
| R027-P1-C078 | Section 1071 data/reporting classifications are not substitutes for §1002.9 classifications, even where numerical thresholds coincide. The May 2026 reporting interpretation expressly says its action-reporting rule does not impair §701(d), §1002.9, or other Subpart A provisions. | S017 comment 109(a)(3)-1.i; S008 §1002.9(a)(3). federalregister.gov+1 |
| R027-P1-C079 | The official scope interpretation generally excludes lending activity outside the United States and includes activity within the United States, Puerto Rico, and U.S. territories/possessions regardless of citizenship. No actual location, cross-border transaction, or separate territorial/foreign-law result is established. | S005 comment 1(a)-2. Consumer Financial Protection Bureau |
The table compares procedures after coverage and transaction classification. Exceptions are cumulative where applicable; an unestablished exception cannot be assumed.
| Issue | Ordinary §1002.9(a)(1)–(2) route, available by election for business credit | Smaller-business route: §1002.9(a)(3)(i) | Larger-business/trade/factoring/similar route: §1002.9(a)(3)(ii) |
|---|---|---|---|
| Entry condition | Creditor follows ordinary notification provisions; business creditors may elect this route. | Preceding-fiscal-year gross revenues at or below $1 million, subject to product exclusions and comment 9(a)(3)-1. | Revenues above $1 million or listed product classification. |
| Completed-application action | 30 days after receipt of completed application. | Same incorporated timing. | Reasonable time after receipt of completed application; ordinary timing is deemed reasonable. |
| Adverse-action delivery | Written ordinary notice. | Action statement may be oral or written; other components follow the incorporated rule and express exceptions. | Action may be oral or written. |
| Reasons furnished with notice | Specific written reasons can satisfy the ordinary alternative. | Available under incorporated rules. | Written reasons/ECOA notice must be supplied on the prescribed timely written request; voluntary fuller disclosure remains possible. |
| Right-to-request alternative | Required disclosure accompanies adverse action when this alternative is used. | Disclosure may instead be provided at application if required content and ECOA notice are included. | Paragraph (ii) does not independently prescribe the ordinary upfront right-to-request disclosure. Preserve statutory framework and actual elected procedure. |
| Request condition | Request within 60 days of notification; this ordinary provision does not demand that the initial request be written. | Incorporated ordinary request mechanics, except where another express provision controls. | Written request within 60 days of notification. |
| Response interval | 30 days after creditor receives the request. | Same. | Statutory receipt-based 30 days, with the textual distinction explained in C039. |
| Oral reasons | Permitted through the ordinary request route with the written-confirmation-right disclosure. | Same incorporated mechanism; telephone and small-volume exceptions require separate checking. | Required response under (ii)(B) is written, subject to a separately applicable express exception such as (d). |
| Entirely telephone application | General telephone-denial interpretation applies where a writing is required. | Express oral action/right-to-reasons alternative. | Already permits oral action; request-response conditions remain separate. |
| Incomplete application | §1002.9(c) alternatives and content apply, subject to express exceptions. | Same. | Do not convert the reasonable-time rule for completed applications into deletion of §1002.9(c). |
| Counteroffer | Standard 90-day provision, acceptance/use condition, and combined-notice alternative. | Incorporated standard provision. | Apply special timing and comment 9(a)(3)-5; ordinary timing is an expressly recognized reasonable route. |
| Record-retention connection | Actual business classification still matters under §1002.12; notice-route election is not a complete retention analysis. | Ordinary business application period, with qualifications. | Special (b)(5) period and timely written-request extension, with other holds preserved. |
Claim crosswalk: C023–C040, C043–C049, C063–C066, C078. Provision links: S008 §1002.9(a)(1)–(3), (c)–(d), comments 9(a)(3)-4–5; S001 §1691(d); S010 §1002.12(b).
| Event | Whose event matters | Provision-level significance |
|---|---|---|
| Receipt of an application | Creditor’s receipt | Can start §1002.9(c)(1) for applicant-completable incompleteness. |
| Completion | Creditor possesses the regularly required information, with reasonable diligence | Starts the completed-application action framework. |
| Adverse action | Creditor’s decision/action | Relevant to incomplete-application and existing-account provisions. |
| Notification | Creditor delivers/mails notice or communicates oral decision | Relevant to the reasons-request period and counteroffer rule. |
| Making a reasons request | Applicant | Must satisfy the applicable form and timeliness condition. |
| Receipt of that request | Creditor | Starts the response interval. |
| Request for written confirmation of oral reasons | Applicant’s written request received by creditor | Separate 30-day confirmation mechanism. |
| Counteroffer acceptance/use | Applicant | Can change whether adverse-action notice remains required. |
| Information supplied after an incompleteness notice | Applicant’s response within the designated period | Determines the next paragraph (a) obligation or permitted closure under paragraph (c). |
These are rule distinctions, not a worked calendar. No holiday adjustment, business-day conversion, constructive-receipt rule, or actual due date is assumed.
| Form | Classification and function | Material content actually read | What proper use still requires |
|---|---|---|---|
| C-4 | Optional sample combining adverse action, reasons, and counteroffer. | Denial of requested terms, reasons, alternative terms, an acceptance period/address, ECOA language, and consumer-report-related portions. | Actual principal reasons; appropriate counteroffer terms; all applicable notice content. It does not establish that an offer must remain open for 90 days. |
| C-5 | Optional sample of adverse action with a right to request specific reasons. | Action statement, contact office, 60-day request period, receipt-based 30-day response, ECOA language, and consumer-report portions. | Correct route, accurate contact information, applicable content, and actual response compliance. |
| C-6 | Optional sample incompleteness notice. | Information needed; date by which it must be received; consequence of no timely response; creditor contact fields. | Applicant-completable missing information, reasonable response period, correct notice timing, and appropriate next action. |
| C-7 | Optional business-credit adverse-action/reasons sample. | Creditor fields, denial statement, reasons space, illustrative collateral/earnings/payment-history categories, and ECOA notice. | Reasons must describe factors actually used. The examples do not establish a valid reason in an unknown application. |
| C-8 | Optional business-credit right-to-reasons disclosure given at application. | Creditor fields, right to written specific reasons, request contact, 60-day request period after decision notification, 30-day response after receipt, and ECOA notice. | Early-disclosure conditions under §1002.9(a)(3)(i)(B); later action notification; appropriate request/response handling. |
Authority and read bounds: C068–C071; S012 Appendix C paragraphs 1–5 and complete C-4–C-8 text. The samples were read as HTML text, not as visually inspected forms. Consumer Financial Protection Bureau+3
Bounded form conclusion: The provisions and appendix read here allow creditor-designed notices and illustrative samples. They do not establish a nationally mandatory single form for this selected framework. That conclusion does not determine requirements under another federal program, state law, contract, or an actual creditor agreement.
| Example family | What the official example establishes | Limit |
|---|---|---|
| Inquiry/prequalification | Explaining terms can remain an inquiry; evaluating and communicating rejection can turn the exchange into an application disposition. | Published examples are consumer examples; no actual business exchange was reviewed. |
| Written-form policy versus oral practice | Actual decision practices count as application procedures. | Does not decide an unidentified creditor’s practices. |
| Missing information | Insufficient decision information can support an incompleteness denial; sufficient information supporting another denial requires the actual reason. | No invented missing documents or underwriting facts. |
| Counteroffer | A combined compliant adverse-action/counteroffer notice can avoid a second notice. | No mandated 90-day offer duration. |
| Trade credit | Supplier financing of its sale differs from financial-institution financing of the same goods. | “Equipment loan” alone does not classify the transaction. |
| Factoring | Receivables purchase differs from credit incident to the arrangement. | No actual contract-characterization conclusion. |
| Current versus past default | Current default on the affected account differs from historical default as a denial reason. | No account status is inferred. |
| Terms versus type | Rejecting requested terms of an offered type can be adverse action. | No obligation to offer every credit type. |
| Scored/judgmental reasons | Reasons follow the factors and decision component actually responsible for the adverse result. | No score reconstruction or model validation. |
| Listed form reason versus actual reason | Selecting an approximate checklist reason does not replace accurate disclosure. | No actual notice deemed compliant or defective. |
Claim links: C005, C009–C014, C025–C026, C046, C049, C056–C059, C070. Source links: S006 relevant §1002.2 comments; S008 complete relevant §1002.9 comments; S012 paragraphs 3–4.
Each row is a qualitative branch, not a fictional application. A/H means generic rule answered; actual classification or compliance held. P/H means a specifically identified public-law boundary remains partial as well as actual facts being held.
| Branch ID / status | Branch and verified rule | Claim/source links | Missing evidence | Adverse inference to avoid | Exact permissible next public-law inquiry |
|---|---|---|---|---|---|
| R027-P1-E001 — A/H | Consumer/business purpose uncertain. Apply primary purpose, including mixed use; a business label alone does not settle it. | C008; S006 §1002.2(g)–(h), comment 2(g)-1. | Purpose, use, applicant statement. | “A business name makes every transaction business credit.” | Examine published interpretations of §1002.2(g) for the abstract mixed-purpose issue; retain actual purpose as unknown. |
| E002 — A/H | Applicant/creditor status unknown. Apply the relevant statutory and regulatory definitions and provision-specific expansions. | C002–C004; S002; S006 §1002.2(e), (l). | Requester/obligor roles; decision participation; assignment role. | “Every intermediary or guarantor automatically owes/receives every notice.” | Compare the definitions and their express cross-reference limits; guarantor litigation/signature issues remain held. |
| E003 — A/H | Application versus inquiry. Actual procedures and the creditor’s evaluative response matter. | C005, C009; S006 comments 2(f)-1–4; S008 comment 9-5. | Exchange content and actual procedures. | “No signed form means no application.” | Read the official inquiry and oral-practice examples without investigating a party. |
| E004 — A/H | Completed versus incomplete. Completion concerns received, regularly considered information; diligence remains required. | C006; S006 §1002.2(f), comment 2(f)-6. | Regular requirements, missing material, receipt and diligence facts. | “Applicant submission proves completion,” or “creditor can delay completion indefinitely.” | Examine necessary approvals/reports and reasonable-diligence language at the generic level. |
| E005 — A/H | Incompleteness notice versus adverse action. Paragraph (c) supplies alternative routes with different content. | C043–C047; S008 §1002.9(c), comments 9(a)(1)-3–4. | Missing information, sufficiency for decision, notice selected. | “A request for more information is always a denial,” or the reverse. | Compare (c)(1)–(3) with the two incompleteness-denial comments. |
| E006 — A/H | Threshold/revenue period unestablished. Use gross revenue in the preceding fiscal year and recognized special classifications. | C023–C024; S008 §1002.9(a)(3), comment 9(a)(3)-1. | Revenue assertion, correct fiscal period, applicant capacity. | “Current-month sales or a calendar-year figure necessarily answers the test.” | Investigate only published interpretations of the §1002.9 revenue predicate; do not import another regime’s definition. |
| E007 — A/H | Revenue versus loan-amount confusion. The notice threshold measures business revenue, not requested credit or collateral. | C023, C078; S008 §1002.9(a)(3). | Correctly labeled measurement and period. | “A loan below $1 million necessarily gets the smaller-business route.” | Compare the exact noun and period in (a)(3)(i)–(ii); no arithmetic is needed. |
| E008 — P/H | Trade/factoring/similar category unestablished. Supplier credit and incidental factoring credit have specific guidance; “similar” is not exhaustively resolved by the read comments. | C025–C026; S008 comments 9(a)(3)-2–3. | Transaction structure; deferred-payment right; actual category. | “Anything financing inventory is trade credit,” or “everything called factoring is outside ECOA.” | Search published agency interpretations of the abstract “other similar types” classification; contract characterization remains held. |
| E009 — A/H | Standard versus special-business procedure. A qualifying creditor may elect stricter standard or smaller-business treatment. | C027–C039; S008 comment 9(a)(3)-4. | Classification and actual compliance route. | “The special procedure is mandatory,” or “it is a complete exemption.” | Compare permissible elections with each route’s content and timing. |
| E010 — A/H | Oral versus written notification. Separate action statement, request-right disclosure, reasons, and written confirmation. | C032–C040, C061; S008 §1002.9(a)(2)–(3), (d); S009 §1002.4(d). | Application channel, component content, volume predicate. | “One permitted oral component makes the whole process oral.” | Apply each express oral alternative to the particular notice component, abstractly. |
| E011 — A/H | Reasons statement versus right-to-request. These are alternative compliance mechanisms, not interchangeable documents without conditions. | C032–C036, C056; S008 §1002.9(a)(2), (b)(2). | Whether reasons were supplied or the prescribed right disclosed. | “An ECOA rights paragraph explains the denial.” | Compare the required elements of (a)(2)(i), (a)(2)(ii), and (b)(1)–(2). |
| E012 — A/H | Actual request versus elapsed period. A request-dependent obligation requires the relevant request, including writing where specified. | C033, C039; S001 §1691(d)(2)(B); S008 §1002.9(a)(3)(ii)(B). | Existence, form, and timeliness of request. | “Waiting 60 days proves a request was made,” or proves waiver of every possible right. | Examine the statutory request condition and the special-business writing requirement; infer no request. |
| E013 — A/H | Request receipt versus response. Request timing and creditor receipt are separate; receipt starts the response interval. | C033–C034, C039, C041. | Notification event, request event, receipt, response. | “The response clock starts at denial,” or automatically at mailing a request. | Read §1691(d)(2)(B) and §1002.9(a)(2)(ii) together; any delivery convention needs a separately established authority. |
| E014 — A/H | Counteroffer accepted versus unaccepted. Express acceptance/use and a combined notice affect subsequent notice duties. | C011, C031, C049; S008 comments 9(a)(1)-5–6. | Acceptance/use, notification, combined content, offer expiration. | “Counteroffer issuance equals acceptance,” or “90 days is the offer’s required life.” | Compare the definition, timing clause, and C-4’s function. |
| E015 — A/H | Third-party/multiple-creditor notice. Acceptance/use of one offer can remove others’ action notices; otherwise each adverse creditor must comply. | C053–C055; S008 §1002.9(g), comments 9(g)-1–3. | Submission roles, decisions, acceptance/use, attribution. | “One approval or one broker letter necessarily excuses everyone.” | Examine the acceptance/use condition and combined-notice attribution requirements. |
| E016 — A/H | Multiple applicants. One notice suffices, directed to an apparent primary applicant. | C004, C052; S008 §1002.9(f). | Applicant status and apparent primary applicant. | “Every signer needs a duplicate,” or “any recipient always suffices.” | Compare §1002.9(f) with the applicant definition; do not adjudicate guarantor status. |
| E017 — A/H | Existing account versus default exception. Determine the action and current status of that same account. | C011–C014, C030. | Action, account relationship, current versus past status. | “Any prior missed payment eliminates all notice rights.” | Read §1002.2(c)(2)(ii) and its current/past-default comment. |
| E018 — A/H | Actual notice content unavailable. Required fields can be identified, but compliance cannot be found without the notice and its route. | C032, C056, C061, C071. | Actual text, delivery form, reason source, appropriate agency. | “A document titled adverse-action notice is compliant,” or defective merely because unavailable. | Compare blank required fields with §1002.9; public law cannot supply unseen notice content. |
| E019 — A/H | Model form versus compliance. Optional samples require proper adaptation and actual reasons. | C068–C070; S012 paragraphs 3–5. | Actual completed content and use. | “Using C-7/C-8 guarantees compliance.” | Examine Appendix C’s proper-use and modification instructions. |
| E020 — A/H | Notice compliance versus discrimination merits. The procedural and substantive inquiries remain distinct. | C001, C014, C074; S001 §1691(a), (c), (d). | Underwriting facts, protected-basis facts, comparative evidence. | “A timely notice proves nondiscrimination,” or “a notice defect establishes every merits element.” | Keep the inquiry confined to procedural elements; merits and remedies remain held. |
| E021 — A/H | State/contract/FCRA overlay. Federal notice duties do not determine all other rights or obligations. | C060, C072; S004 §1691d(f)–(g); S014 §1002.11. | Jurisdiction, applicable exemption, contract, report use. | “ECOA compliance resolves every notice or contract issue.” | Examine federal preservation/exemption language only; state, contract, and full FCRA investigations remain held. |
| E022 — A/H | Startup, sole proprietor, or individual business applicant. The official comment supplies distinct routing instructions. | C024; S008 comment 9(a)(3)-1. | Capacity, startup character, revenue statement, product category. | “No prior revenue automatically removes notice protection.” | Apply the comment’s separate categories without inventing revenue. |
| E023 — A/H | Express withdrawal versus special approved-application withdrawal. The latter requires all stated predicates and is optional. | C050–C051; S008 comment 9-2; §1002.9(e). | Express withdrawal or approval/status-inquiry arrangement. | “Silence always withdraws an application.” | Compare express withdrawal, (e), and incompleteness closure separately. |
| E024 — A/H | Utilities/securities/incidental/government exceptions. Each has its own definition and exception list. | C015–C018; S007 §1002.3(a)–(d). | Qualifying category predicates. | “Every nonconsumer transaction is exempt,” or “government funding means government credit.” | Read the complete definition and exception list for the abstract class, without identifying a provider. |
| E025 — A/H | Small-volume creditor. The test is prior-calendar-year received applications, separate from business revenue. | C040; S008 §1002.9(d); S001 §1691(d)(5). | Application count and correct year. | “A small loan or small business proves the creditor qualifies.” | Compare statute and implementing count language; retain actual volume as unknown. |
| E026 — A/H | Retained content and special request. Reasons requests and retention-only requests have different purposes; additional retention predicates remain. | C021, C063–C066; S010 §1002.12(b)(1)–(5). | Record type, notice event, written request, other holds. | “60 days permits destruction of everything,” or “retention request automatically requests reasons.” | Reconcile only the specified application-record clauses; full retention schedule remains held. |
| E027 — A/H | Preapproval exception. A qualifying preapproval application has a narrow incompleteness-notice exception. | C010, C048; S006 comment 2(f)-5; S008 comment 9(c)(1)-1. | Program commitment and condition structure. | “Preapproval is never an application,” or “all notices disappear.” | Compare the complete official preapproval example with the narrow exception. |
| E028 — A/H | Inadvertent error. Preventive procedures, unintentional error, and correction duties matter; legal misjudgment is excluded. | C073; S006 §1002.2(s); S015 §1002.16(c). | Nature of error, procedures, discovery, correction. | “Calling a mistake inadvertent establishes the exception.” | Examine the defined error and official examples without making a liability finding. |
| E029 — P/H | Federal geographic or dealer boundary. Location and the §5519 classification can affect the relevant regulatory instrument. | C019, C079; S005; S021. | Activity location and statutory role/function predicates. | “A U.S. applicant or vehicle-related loan automatically resolves scope.” | Update the published §5519 cross-reference if needed; Part 202, foreign, and territorial law remain separate held work. |
| E030 — A/H | Section 1071 versus notification rules. Separate reporting definitions and future compliance dates do not replace §1002.9. | C075–C078; S016–S020. | Which provision an asserted classification actually invokes. | “Removal of a reporting data point abolishes reasons notices.” | Examine the May 2026 rule’s amendment directions and preservation sentence; do not conduct a full Subpart B investigation. |
Purpose: a blank structure for later authorized review. It is not a completed application, request, notice, compliance opinion, or record request. All factual entries remain blank.
| Field | Blank entry | Governing check |
|---|---|---|
| Federal source/version used | ______ | S001–S021; C075–C078 |
| Activity within relevant federal geographic scope | ______ | C079 |
| Applicant role established | ______ | C002, C004 |
| Creditor decision-making role established | ______ | C003 |
| Part 1002/§1029 boundary addressed | ______ | C019 |
| Deferred-payment credit element | ______ | C002, C008 |
| Primary purpose and basis for classification | ______ | C008 |
| §1002.3 category, if any, and exact predicates | ______ | C015–C018 |
| Business capacity: startup / proprietor / individual / other | ______ | C024 |
| Gross-revenue assertion and preceding fiscal period | ______ | C023–C024 |
| Trade / credit incident to factoring / similar classification | ______ | C025–C026 |
| Notice procedure elected | ______ | C027, C035–C039 |
| Small-volume oral exception predicate | ______ | C040 |
| Event | Relevant generic actor | Evidence reference | Event established? |
|---|---|---|---|
| Application received | Creditor | ______ | ______ |
| Information requirements and diligence established | Creditor | ______ | ______ |
| Completed application received | Creditor | ______ | ______ |
| Applicant-completable information missing | Applicant/creditor | ______ | ______ |
| Action taken | Creditor | ______ | ______ |
| Action communicated | Creditor | ______ | ______ |
| Incompleteness notice and reasonable response period | Creditor | ______ | ______ |
| Requested information supplied | Applicant | ______ | ______ |
| Counteroffer communicated | Creditor | ______ | ______ |
| Counteroffer expressly accepted or used | Applicant | ______ | ______ |
| Express withdrawal or §1002.9(e) predicates | Applicant/creditor | ______ | ______ |
| Reasons request made; form of request | Applicant | ______ | ______ |
| Reasons request received | Creditor | ______ | ______ |
| Reasons response provided | Creditor | ______ | ______ |
| Written-confirmation request received | Creditor | ______ | ______ |
| Written confirmation provided | Creditor | ______ | ______ |
| Required or conditional element | Blank finding |
|---|---|
| Correct action statement | ______ |
| Creditor identification/address required by selected route | ______ |
| Applicable ECOA notice | ______ |
| Appropriate federal agency identification/address | ______ |
| Actual principal reasons or compliant request-right disclosure | ______ |
| Correct request contact information | ______ |
| Oral-reasons written-confirmation right, if applicable | ______ |
| Incompleteness information, reasonable period, and consequence | ______ |
| Multiple-applicant recipient condition | ______ |
| Multiple-creditor identities and reason attribution | ______ |
| Clear/conspicuous and retainable writing, if applicable | ______ |
| Applicable electronic-form requirements separately addressed | ______ |
| Model adapted to actual reasons rather than approximate checklist selection | ______ |
| Separate FCRA/state/contract notice questions preserved | ______ |
| Field | Blank entry |
|---|---|
| Applicable §1002.12 application/account category | ______ |
| Correct retention trigger identified | ______ |
| Reasons request versus retention-only request distinguished | ______ |
| Subpart B and other retention holds preserved | ______ |
| Inadvertent-error predicates and correction, if raised | ______ |
| Unresolved classification issues | ______ |
| Unresolved source/currentness issues | ______ |
| Actual compliance determination authorized and supported? | ______ |
| Independent qualified review completed? | ______ |
No calendar or arithmetic illustration is included. A worked deadline would require facts and conventions not established here. The worksheet deliberately keeps notification, request-making, request receipt, and response events separate.
This table addresses every numbered instruction. Section 5 separately supplies granular coverage for every material branch requested.
| Question / material subquestion | Status | Findings and evidence | Missing evidence or limit | Exact permissible next investigation |
|---|---|---|---|---|
| 1 — ECOA/Regulation B coverage and actors | Answered generically | C001–C008, C019, C079; S001–S006, S021. | Actual roles, purpose, location, and §5519 classification unknown. | Update the relevant published definition/cross-reference if necessary; no party search. |
| 1 — Application, completion, inquiry, adverse action | Answered generically | C005–C014; S006, S008. | Actual procedure, information, and decision facts held. | Compare official application and adverse-action examples with abstract categories only. |
| 1 — Complete necessary statutory clauses and material exceptions | Answered within stated bounds | S001–S004; C015–C022, C072–C074. Complete §1002.3 and §1002.9 read. | No exhaustive grant-of-exemption or judicial-history audit. | Published amendment/exemption instruments only, if a specific public-law issue warrants it. |
| 1 — §1002.12/.13 and adjacent provisions | Answered narrowly; remainder excluded | C061–C067, C073; S009–S011, S015. | Full retention, monitoring, privacy, E-Sign, and section 1071 work held. | Investigate only a necessary notice cross-reference; preserve the broader holds. |
| 2 — Revenue threshold, period, startup/proprietor/individual | Answered generically | C023–C024; E006–E007, E022. | Actual revenue, period, and capacity absent. | Published §1002.9 interpretations; no invented calculation or imported small-business definition. |
| 2 — Trade/factoring/similar classification | Answered for express examples; partial for undefined edge cases | C025–C026; E008. | No exhaustive definition of “other similar types” established. | Search official published classification interpretations for the abstract product issue. |
| 2 — Oral/written, action timing, request and response | Answered with textual distinctions | C028–C041; S001, S008, S019; comparison table. | Actual notification/request/receipt dates unknown; no calendaring conventions selected. | Further official timing interpretation only if needed; no actual deadline finding. |
| 2 — Retainable disclosures and retained records | Answered narrowly | C061, C063–C066, C021. | Record category and other holds unknown. | Focused statutory/regulatory reconciliation; no destruction permission. |
| 2 — Complete relevant §1002.9 comments/examples | Answered | Full comment inventory in S008; C024–C027, C041–C060. | No system, notice, or application evidence. | No further source expansion needed to state the generic framework. |
| 3 — Incomplete application versus action notice | Answered | C029, C043–C048; E004–E005, E027. | Missing-information and sufficiency predicates unknown. | Official paragraph (c) and preapproval interpretations only. |
| 3 — Counteroffers/acceptance/expiration | Answered | C011, C031, C049; E014. | No counteroffer or acceptance facts. | Examine the combined-notice provision and special-route timing where necessary. |
| 3 — Multiple applicants and third parties | Answered | C052–C055; E015–E016. | Actual primary applicant, creditor decisions, and acceptance/use absent. | Definitions and published multiple-creditor interpretations only. |
| 3 — Withdrawal and existing accounts | Answered | C014, C030, C050–C051; E017, E023. | No withdrawal, approval, status-inquiry, or default facts. | Distinguish the express regulatory predicates; no status search. |
| 4 — Relevant model notices/instructions | Answered within complete C-4–C-8 text bounds | C068–C071; S012–S013; Section 4. | No actual notice; C-1–C-3 not fully audited; no form pixels inspected. | Additional official sample only if a distinct notice function becomes necessary. |
| 4 — Mandatory versus optional form and edition | Answered, bounded | Appendix C paragraph 5; current online codified edition; S018 contact amendment. | No universal statement about every program or jurisdiction. | A separately authorized program-specific public-law form inquiry, if needed. |
| 5 — Comparison and blank audit worksheet | Completed | Sections 3 and 6. | All transaction entries intentionally blank. | None necessary for the blank deliverable. |
| 5 — At least twelve substantive branches | Completed: 30 branches | Section 5, E001–E030, each with rule, claim/source crosswalk, missing evidence, inference to avoid, and public-law next inquiry. | Actual applications remain held throughout. | Only the bounded next inquiry stated in the relevant row. |
| Currentness requirement | Answered with express limits | S016–S020; C075–C078; access date above. | Post-compilation legislation/rules and comprehensive later judicial history not exhaustively audited. | Official current-body/amendment update; no case-record/docket query. |
| Parent A027 dimensions and acceptance | Excluded by instruction | Holds below. | All uninvestigated products, jurisdictions, merits, and operational facts. | Separate authorization and scope would be required for a different component. |
| Log ID | Event | Result and treatment |
|---|---|---|
| R027-P1-L001 | Initial legacy OLRC URLs: https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1691; https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1691a; https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1691b; https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1691d. | Returned 404 failures. Recovered through normal public OLRC navigation to S001–S004. Failure was not treated as absence of statutory law. |
| L002 | Initial direct opens of short/current OLRC routes and some versioned routes. | Several returned “not accessible via this tool.” Normal public statute navigation subsequently retrieved the versioned bodies used in S002–S004. No authentication or security bypass. |
| L003 | https://uscode.house.gov/us/usc/t12/s5519/. | Direct retrieval failed. An official indexed version through Oct. 15 was opened and read as S021; that currency limit remains explicit. |
| L004 | FDIC examination manual: https://www.fdic.gov/consumer-compliance-examination-manual/v-7-equal-credit-opportunity-act-ecoa. | Search returned text, but direct opening returned 403 Forbidden. No claim of full-body review; it is not a necessary foundation for the claims. |
| L005 | CFPB interactive Regulation B pages. | Retrieved successfully. Publisher’s update-lag notice prompted comparison with eCFR and the 2026 final-rule amendment instructions. |
| L006 | eCFR sections and Appendix C. | Relevant bodies retrieved. Currency stamps varied by retrieved snapshot, as recorded. These are authoritative online presentations but are not described here as official legal editions of the CFR. |
| L007 | Federal Register HTML and govinfo PDFs. | Selected final-rule dates and operative amendment bounds read. Parsed PDF text was used; no pixel inspection and no full-PDF read claim. |
| L008 | CFPB October 2015 examination PDF. | Successful retrieval exposed the reference-only cover. Classified historical and excluded as a current-law foundation. |
| L009 | Long or initially clipped search/open outputs. | Targeted follow-up opens supplied the material operative clauses and complete relevant §1002.9 comments. An initial search excerpt was not treated as a complete read. |
| L010 | Court opinions, dockets, party records, actual forms/applications, and prior reports. | No case-record/docket or party query was performed. No published opinion was needed for the selected generic notice framework. No actual application was obtained or completed. |
I checked the report for the following distinctions:
All parent holds remain in place. This report supplies no component, parent, operational, or publication acceptance, and no independent qualified-review representation.
END R027 PASS-01
Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
Status · Treatment in this investigation · 8 data rows
| Status | Treatment in this investigation |
|---|---|
| Current codified provisions | Used within the retrieved compilation dates and the clause-specific bounds below. |
| Final rules with effective dates already reached | Checked for changes affecting this component. |
| Future compliance obligations | The May 2026 rule’s section 1071 compliance date was identified only to prevent importing it into current §1002.9 notices. |
| Historical materials | Identified explicitly; not silently substituted for current regulatory text. |
| Proposed provisions | Not treated as operative law. |
| Withdrawn/reference-only guidance | The retrieved October 2015 CFPB examination PDF carried a reference-only notice; it was excluded as a current-law foundation. |
| Stayed, vacated, or later judicially limited provisions | No comprehensive later-history or litigation-status conclusion is made. No case-record or docket query was performed. |
| Unknown | Actual transaction classifications, applicable state exemptions, any post-compilation amendment not reflected in the retrieved bodies, and transaction-specific legal consequences remain unknown. |
Source ID · Issuer/title and complete literal HTTPS URL · Exact material read and relied-on bounds · 5 data rows
| Source ID | Issuer/title and complete literal HTTPS URL | Exact material read and relied-on bounds | Version, effectiveness, status, and limits |
|---|---|---|---|
| R027-P1-S001 | U.S. House, Office of the Law Revision Counsel — 15 U.S.C. §1691, Scope of prohibition. https://uscode.house.gov/us/usc/119-134/t15/s1691/ | Operative subsections (a)–(d) read completely, especially (d)(1)–(6). Subsection (e) and editorial/effective-date notes also appeared and were read for boundary identification; appraisal obligations are excluded from substantive coverage. | Compilation through P.L. 119-134, Oct. 20, 2026. Statute, not agency guidance. No comprehensive session-law or judicial audit. uscode.house.gov |
| R027-P1-S002 | OLRC — 15 U.S.C. §1691a, Definitions; rules of construction. https://uscode.house.gov/us/usc/119-134/t15/s1691a/ | (a)–(g) completely, including applicant, credit, creditor, person, and incorporation of regulations. | Same Oct. 20, 2026 compilation predicate. Statutory definitions are distinguished from Regulation B’s definitions. uscode.house.gov |
| R027-P1-S003 | OLRC — 15 U.S.C. §1691b, Promulgation of regulations by the Bureau. https://uscode.house.gov/us/usc/119-134/t15/s1691b/ | (a)–(g) completely. Material provisions: classification/exception authority (a)–(c); records (d); business-loan denial notice (e); reserved Board authority (f). | Same Oct. 20 compilation. Subsection (g) was read but no judicial-deference conclusion is made. Full recordkeeping and remedies remain held. uscode.house.gov |
| R027-P1-S004 | OLRC — 15 U.S.C. §1691d, Applicability of other laws. https://uscode.house.gov/us/usc/119-134/t15/s1691d/ | (a)–(g) completely. Reliance here is principally on (f)–(g). Signature, marital-property, finance-charge aggregation, and remedy provisions were read to preserve boundaries, not applied. | Same Oct. 20 compilation. Earlier Oct. 7 snapshot was superseded for this report by successful retrieval of this version. uscode.house.gov |
| R027-P1-S021 | OLRC — 12 U.S.C. §5519, Exclusion for auto dealers. https://uscode.house.gov/us/usc/119-124/t12/s5519/ | (a)–(f) completely; necessary cross-reference for §1002.1(a), including the exclusion, functional exceptions, preserved authority, and statutory definitions. | Retrieved compilation through P.L. 119-124, Oct. 15, 2026. No actual dealer classification, license search, vehicle classification, or complete Part 202 investigation. The later compilation interval remains a source limit. uscode.house.gov |
Source ID · Issuer/title and complete literal HTTPS URLs · Exact material read and relied-on bounds · 11 data rows
| Source ID | Issuer/title and complete literal HTTPS URLs | Exact material read and relied-on bounds | Version/status and limits |
|---|---|---|---|
| R027-P1-S005 | CFPB/OFR-GPO — §1002.1, Authority, scope and purpose, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.1; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-1/ | Entire (a)–(b); comments 1(a)-1 through -3. | eCFR snapshot through Oct. 23, 2026. Official interpretation distinguished from statutory text. Geographic discussion concerns federal applicability only. ecfr.gov +1 |
| R027-P1-S006 | §1002.2, Definitions, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.2; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-2/ | Regulatory definitions read, with reliance on (a), (c), (e)–(j), (l)–(m), (q), (s), (w), (x), (z), (aa). Complete relevant comments: 2(c)(1)(i)-1; 2(c)(1)(ii)-1–2; 2(c)(2)(ii)-1–2; 2(c)(2)(iii)-1–2; 2(c)(2)(v)-1; 2(e)-1; 2(f)-1–6; 2(g)-1; 2(j)-1; 2(l)-1–2. | eCFR through Oct. 26, 2026. The separate scoring-validity and discrimination-merits investigation is held. The April 2026 changes to comment 2(p) are not imported into this notice analysis. ecfr.gov +4 |
| R027-P1-S007 | §1002.3, Limited exceptions, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.3; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-3/ | Entire (a)–(d), including definitions and exception lists; all displayed substantive comments: 3-1; 3(a)-1–3; 3(c)-1; 3(d)-1. | eCFR through Oct. 26, 2026. Narrow Regulation Z cross-reference identified; no independent finance-charge calculation or securities-law analysis. ecfr.gov +1 |
| R027-P1-S008 | §1002.9, Notifications, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.9; https://www.consumerfinance.gov/rules-policy/regulations/1002/9/; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-9/ | Entire (a)–(g). Complete comments 9-1–5; 9(a)(1)-1–7; 9(a)(3)-1–5; 9(b)(1)-1; 9(b)(2)-1–9; 9(c)(1)-1; 9(c)(2)-1; 9(c)(3)-1; 9(g)-1–3, including examples. | eCFR through Oct. 26, 2026. Section’s amendment note identifies the 2023 technical amendment; S018 verifies its effective date and scope. No actual notice or request was reviewed. ecfr.gov +3 |
| R027-P1-S009 | §1002.4, General rules. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.4 | (a), (c)–(e); current (b) was visible but its merits are held. Material reliance: written applications, clear/conspicuous and retainable disclosures, electronic-form cross-reference, language. | eCFR through Oct. 26, 2026; incorporates April 2026 amendment effective July 21. No full E-Sign compliance analysis. ecfr.gov |
| R027-P1-S010 | §1002.12, Record retention, and official interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.12; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-12/ | Complete (b)(1)–(5); comments 12(b)-1–2 and 12(b)(3)-1. Other displayed provisions were not developed into a full recordkeeping investigation. | Snapshot through Oct. 23, 2026. Express Subpart B qualifications preserved. No destruction authorization or complete privacy/retention schedule. ecfr.gov +1 |
| R027-P1-S011 | §1002.13, Information for monitoring purposes, and interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.13; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-13/ | Regulatory (a)–(d) read; relevant comments 13(a)-1–5 read. Used only for the monitoring/application-form boundary. | Retrieved snapshot through Oct. 22, 2026. No protected-characteristic data obtained; no HMDA or section 1071 investigation. ecfr.gov +1 |
| R027-P1-S012 | Appendix C, Sample Notification Forms. https://www.consumerfinance.gov/rules-policy/regulations/1002/c/; https://www.ecfr.gov/current/title-12/chapter-X/part-1002/appendix-Appendix%20C%20to%20Part%201002 | Introductory paragraphs 1–5; complete HTML text of C-4, C-5, C-6, C-7, C-8. CFPB parsed bounds: C-4 lines 293–330; C-5 331–379; C-6 380–394; C-7 395–409; C-8 410–417. | Current online codified samples, latest checked eCFR snapshot through Oct. 26, 2026. Appendix amendment note: 2011 and 2013; not a newly revised “2026 form.” No form PDF or pixels inspected. C-1–C-3 were identified by the introduction, not fully audited. Consumer Financial Protection Bureau +4 |
| R027-P1-S013 | Appendix A, Federal Agencies To Be Listed in Adverse Action Notices. https://www.consumerfinance.gov/rules-policy/regulations/1002/a/ | Introductory scope and displayed initial classifications, particularly the statement that the list identifies notice agencies and is not a description of all enforcement authority. | Current online text, with 2023 amendment timing verified in S018. No agency was selected for an actual creditor; no creditor roster consulted. Consumer Financial Protection Bureau |
| R027-P1-S014 | §1002.11, Relation to state law. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.11 | (a)–(e) read; reliance limited principally to (a), (e) and preservation boundaries. | Snapshot through Oct. 23, 2026. No state-law survey, state exemption determination, or remedy assessment. ecfr.gov |
| R027-P1-S015 | §1002.16(c), Failure of compliance, and interpretation. https://www.ecfr.gov/current/title-12/chapter-X/part-1002/subpart-A/section-1002.16; https://www.consumerfinance.gov/rules-policy/regulations/1002/interp-16/ | Complete (c) and comments 16(c)-1–2, with §1002.2(s). Other enforcement/remedy text was not applied. | eCFR through Oct. 23, 2026. Narrow error exception only; no actual liability determination. ecfr.gov +1 |
Source ID · Issuer/title and complete literal HTTPS URLs · Exact read bounds · 6 data rows
| Source ID | Issuer/title and complete literal HTTPS URLs | Exact read bounds | Status and limits |
|---|---|---|---|
| R027-P1-S016 | CFPB — Equal Credit Opportunity Act (Regulation B), April 22, 2026, 91 FR 21620. https://www.federalregister.gov/documents/2026/04/22/2026-07804/equal-credit-opportunity-act-regulation-b; https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07804.pdf | Dates/summary; amendment instructions 1–6, printed 21668–21669; narrow current comment 8(b)-1, printed 21670. PDF parsed excerpts at index 0, 48–49; corresponding operative HTML read. | Final; effective July 21, 2026. Changes §1002.4(b), §1002.6(a), specified §1002.8/§1002.15 provisions and interpretations; no §1002.9 amendment in these instructions. Full merits/preamble and judicial history excluded. govinfo.gov +3 |
| R027-P1-S017 | CFPB — Small Business Lending Under ECOA, May 1, 2026, 91 FR 23530. https://www.federalregister.gov/documents/2026/05/01/2026-08494/small-business-lending-under-the-equal-credit-opportunity-act-regulation-b; https://www.govinfo.gov/content/pkg/FR-2026-05-01/pdf/2026-08494.pdf | Dates/summary; complete amendment-direction sequence 1–13, printed 23604–23609; narrow comment 109(a)(3)-1.i preserving §701(d)/§1002.9. PDF parsed excerpts: index 0, 74–75, 78–79; other direction text read in HTML. | Final; effective June 30, 2026; stated compliance date Jan. 1, 2028. Subpart B investigation remains held. No §1002.9 amendment in the directions. No full 97-page read or pixel claim. govinfo.gov +3 |
| R027-P1-S018 | CFPB — Agency Contact Information, March 20, 2023, 88 FR 16531. https://www.federalregister.gov/documents/2023/03/20/2023-05216/agency-contact-information; https://www.govinfo.gov/content/pkg/FR-2023-03-20/pdf/2023-05216.pdf | Dates at printed 16531, PDF index 0; HTML section IV.A and amendment instructions 3–4, printed 16537, concerning §1002.9(b)(1) and Appendix A. | Final technical rule; effective Apr. 19, 2023; Appendix A mandatory compliance Mar. 20, 2024. Other regulations in this rule excluded. federalregister.gov +2 |
| R027-P1-S019 | Federal Reserve Board — Background and Summary of Regulation B, Federal Reserve Regulatory Service. https://www.federalreserve.gov/frrs/regulations/background-and-summary-of-regulation-b.htm | Business-credit discussion 6-142.2–6-142.4, especially “Applicants with Revenues of More than $1 Million.” HTML lines 3815–3831. | Agency explanatory summary using Part 202 numbering, not the current Part 1002 regulation or a statute. Edition date not established. Used narrowly to corroborate the receipt-based 30-day reasons-response reading of §1691(d)(2)(B), not to replace current law. federalreserve.gov |
| R027-P1-S020 | CFPB — 12 CFR Part 1002 landing page. https://www.consumerfinance.gov/rules-policy/regulations/1002/ | Currentness notices, links to the two 2026 final rules, and legal-edition disclaimer. | Publisher status/context only. Its “most recently amended July 21, 2026” statement is not a complete amendment or judicial-history audit. Consumer Financial Protection Bureau |
| R027-P1-S022 | CFPB — October 2015 ECOA narrative and examination procedures. https://files.consumerfinance.gov/f/201510_cfpb_ecoa-narrative-and-procedures.pdf | Parsed cover, PDF index 0; narrow examination question 46, printed Procedures 23, PDF index 36. | Historical/reference-only. Cover explains that related bulletin material has no force or effect. Not used as a current-law foundation; no full-document or pixel inspection claim. files.consumerfinance.gov +1 |
Claim ID · Verified proposition, conditions, and exceptions · Exact authority · 14 data rows
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C001 | ECOA addresses discrimination in any aspect of a credit transaction, and Regulation B reaches commercial as well as personal credit. Coverage establishes regulatory duties; the notification provisions do not themselves promise that an application will be approved. | S001 §1691(a), (d); S005 §1002.1(a)–(b), comment 1(a)-1. uscode.house.gov +1 |
| R027-P1-C002 | Statutory “applicant” includes a person applying directly for an extension, renewal, or continuation, and specified indirect applications exceeding an existing limit. Statutory “credit” concerns a right to defer payment. “Person” includes natural persons and the listed organizational/governmental forms. Statutory “creditor” includes regular extenders, arrangers, and participating assignees. | S002 §1691a(b), (d)–(f). uscode.house.gov |
| R027-P1-C003 | For Regulation B, a creditor ordinarily regularly participates in credit decisions, including setting terms; participating assignees, transferees, and subrogees are included. The additional inclusion of referral/selection intermediaries is expressly for §1002.4(a)–(b). Mere referral status should not automatically be converted into a §1002.9 notice obligation. | S006 §1002.2(l), comments 2(l)-1–2. ecfr.gov +1 |
| R027-P1-C004 | Regulation B’s applicant definition covers a person requesting or receiving credit and persons who are or may become contractually liable. Its express inclusion of guarantors, sureties, endorsers, and similar parties is stated for §1002.7(d). This report makes no independent guarantor-notice or signature ruling. | S006 §1002.2(e), (i). ecfr.gov |
| R027-P1-C005 | An application is an oral or written credit request made under the creditor’s procedures for that credit type. “Procedures” includes actual practices, not merely a stated written-form policy. A creditor that actually decides oral requests cannot disregard that practice solely because its policy calls for a form. | S006 §1002.2(f), comments 2(f)-1–2. ecfr.gov +1 |
| R027-P1-C006 | Completion turns on the creditor having received all information it regularly obtains and considers for the requested amount/type, including necessary third-party reports or guarantee/security approvals. The creditor must exercise reasonable diligence in obtaining it. Submission of an applicant’s form alone does not necessarily establish completion; creditor delay does not erase the diligence duty. | S006 §1002.2(f), comment 2(f)-6; S008 comment 9(a)(1)-1. ecfr.gov +2 |
| R027-P1-C007 | Use of an account or credit line within an established limit is excluded from the application definition. A procedurally valid application to increase available credit is different; refusal of that request may be adverse action. | S006 §1002.2(f), (c)(1)(iii), comment 2(c)(2)(iii)-2. ecfr.gov +1 |
| R027-P1-C008 | Business credit is primarily for business/commercial purposes, including agriculture, excluding the classes in §1002.3(a)–(d). Consumer credit is credit to a natural person primarily for personal, family, or household purposes. Mixed use requires a primary-purpose determination; the creditor may rely on the applicant’s purpose statement. | S006 §1002.2(g)–(h), comment 2(g)-1. ecfr.gov +1 |
| R027-P1-C009 | The official inquiry/prequalification examples distinguish discussion of general terms from evaluating information, deciding to reject, and communicating that decision. The creditor’s response matters; calling the exchange an “inquiry” does not control its legal classification. The published examples are consumer examples, not an actual business-credit finding. | S006 comments 2(f)-3–4; S008 comment 9-5. Consumer Financial Protection Bureau +1 |
| R027-P1-C010 | The official preapproval example involves comprehensive creditworthiness review and a written commitment for a designated period, subject only to the specified collateral, no-material-change, and limited ordinary conditions. Denial under that program is also an application disposition. A program without written commitments is treated as prequalification under the comment. | S006 comment 2(f)-5(i)–(ii). Consumer Financial Protection Bureau |
| R027-P1-C011 | Regulatory adverse action includes refusal of substantially the amount/terms requested, subject to an accepted-or-used counteroffer; termination or an unfavorable account change not affecting all/substantially all of a class; and refusal of an applied-for increase. | S006 §1002.2(c)(1)(i)–(iii); S001 §1691(d)(6). ecfr.gov +1 |
| R027-P1-C012 | Exclusions include expressly agreed account changes; action connected with inactivity/default/delinquency on that account; specified point-of-sale/loan authorization refusals; credit prohibited by applicable law; and a credit type/plan the creditor does not offer. The stated point-of-sale exceptions must also be checked. If both inclusion and exclusion apply, §1002.2(c)(2) governs. | S006 §1002.2(c)(2)–(3). ecfr.gov |
| R027-P1-C013 | Refusing requested terms of an offered credit type is different from not offering that type of credit. Denial because of requested rate, maturity, collateral, or down payment is adverse action unless an applicable counteroffer exception applies. Refusal to refinance or extend a business loan’s term is adverse action when the applicant followed the creditor’s application procedures. | S006 comments 2(c)(2)(v)-1 and 2(c)(1)(i)-1. Consumer Financial Protection Bureau +1 |
| R027-P1-C014 | The account-default exception concerns current default or delinquency on that account. The interpretation says notification generally is required when action is based on a past delinquency/default. Neither historical payment trouble nor default on some unidentified account establishes the exception. | S006 §1002.2(c)(2)(ii), comment 2(c)(2)(ii)-2. ecfr.gov +1 |
Claim ID · Verified proposition, conditions, and exceptions · Exact authority · 8 data rows
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C015 | Qualifying public-utilities credit requires the specified utility-service delivery and governmental filing/regulation of charges. Its listed exceptions concern marital-status information and record retention; §1002.9 is not among them. Utility financing of equipment or other goods is not automatically within the utility-service exception. | S007 §1002.3(a)(1)–(2), comments 3(a)-1–3. ecfr.gov +1 |
| R027-P1-C016 | Securities credit has a specific statutory/regulatory classification and a list of exceptions. That list does not except §1002.9. Its exclusion from the definition of “business credit” must not be mistaken for exclusion from all Regulation B procedures. | S007 §1002.3(b); S006 §1002.2(g). ecfr.gov +1 |
| R027-P1-C017 | Incidental credit under §1002.3(c) is consumer credit, outside the utility/securities categories, not under a credit-card account, without a Regulation Z finance charge, and not contractually payable in more than four installments. Qualifying incidental credit is excepted from §1002.9. These conditions cannot simply be transferred to business trade credit. | S007 §1002.3(c)(1)–(2), comment 3(c)-1. ecfr.gov +1 |
| R027-P1-C018 | “Government credit” means credit to governments and their listed subdivisions/agencies/instrumentalities. Except for §1002.4(a), the regulation’s requirements do not apply to that class. Credit by a government agency does not qualify merely because of the creditor’s governmental status. | S007 §1002.3(d), comment 3(d)-1. ecfr.gov +1 |
| R027-P1-C019 | Part 1002 excludes persons covered by the §1029/§5519 dealer exclusion, with statutory functional exceptions. Section 5519(b) preserves specified mortgage/real-property services, certain direct retail-credit/leasing businesses whose contracts are not routinely assigned to unaffiliated finance sources, and unrelated consumer financial products. This is not an exemption from ECOA itself; §1691b(f) preserves Board rulemaking. | S005 §1002.1(a), comment 1(a)-1; S021 §5519(a)–(c), (f); S003 §1691b(f). No actual dealer classification. Consumer Financial Protection Bureau +2 |
| R027-P1-C020 | Section 1691b grants classification, differentiation, adjustment, and exception authority. Subsections (b)–(c) address exemption findings and duration, including a five-year limit and a subsequent determination for extension. They do not themselves establish that an unidentified business transaction has a blanket exemption. | S003 §1691b(a)–(c); actual regulatory classes in S007–S008. uscode.house.gov |
| R027-P1-C021 | Section 1691b(d) directs business/commercial lenders to maintain compliance-related records under regulations and states a minimum one-year period for the records/data it addresses. The application-specific regulation separately contains §1002.12(b)(5). This report preserves both texts and does not turn the special application rule into universal authorization to discard all business-loan records after 60 days. | S003 §1691b(d); S010 §1002.12(b)(1)–(5). uscode.house.gov +1 |
| R027-P1-C022 | Section 1691b(e) directs the Bureau to provide by regulation written notice of a business/commercial loan applicant’s right to a written denial-reasons statement. The actual procedural implementation must be read with §1002.9’s alternatives and exceptions, including the entirely-telephone and small-volume provisions. | S003 §1691b(e); S008 §1002.9(a)(3), (d). uscode.house.gov +1 |
Claim ID · Verified proposition, conditions, and exceptions · Exact authority · 20 data rows
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C023 | Section 1002.9(a)(3)(i) addresses a business with gross revenues of $1 million or less in its preceding fiscal year, excluding trade credit, credit incident to factoring, and similar business credit. Subparagraph (ii) addresses revenues over $1 million, or those listed credit categories. This is a revenue-and-period test, not a loan-amount, limit, balance, collateral, or net-profit test. | S008 §1002.9(a)(3)(i)–(ii). ecfr.gov |
| R027-P1-C024 | The creditor may rely on the applicant’s revenue assertion. Comment 9(a)(3)-1 directs startup applications to (i); sole-proprietor applications use the proprietorship’s revenues; an individual applying for business credit uses (i) unless trade/similar credit. Product exceptions still require separate classification. | S008 comment 9(a)(3)-1. Consumer Financial Protection Bureau |
| R027-P1-C025 | Trade credit generally means buyer–seller financing, such as a supplier financing its sale of equipment, supplies, or inventory. A bank or other financial institution financing those same items is not thereby extending “trade credit” under this interpretation. | S008 comment 9(a)(3)-2. Consumer Financial Protection Bureau |
| R027-P1-C026 | The interpretation describes factoring as a purchase of receivables and therefore outside the Act/regulation. A credit extension incident to factoring is different: §1002.9(a)(3)(ii) and other relevant provisions apply. A product label alone does not establish which transaction occurred. | S008 comment 9(a)(3)-3; S006 §1002.2(j). Consumer Financial Protection Bureau +1 |
| R027-P1-C027 | A business-credit creditor may elect to follow the consumer notification rules. It may also treat all business credit under §1002.9(a)(3)(i), irrespective of revenue size. Those are permitted compliance routes; the special route is not compulsory merely because the applicant exceeds the threshold. | S008 comment 9(a)(3)-4. Consumer Financial Protection Bureau |
| R027-P1-C028 | Under §1002.9(a)(1)(i), notice of approval, counteroffer, or adverse action is due within 30 days after the creditor receives a completed application. The smaller-business route incorporates this timing. The larger/trade route has the reasonable-time alternative described in C038. | S008 §1002.9(a)(1)(i), (a)(3)(i), comment 9(a)(1)-1. ecfr.gov +1 |
| R027-P1-C029 | Section 1002.9(a)(1)(ii) measures 30 days from taking adverse action on an incomplete application, unless the paragraph (c) route is used. Paragraph (c)(1) independently addresses the initial receipt of an applicant-completable incomplete application; the two provisions cannot be stacked into an assumed extra waiting period. | S008 §1002.9(a)(1)(ii), (c)(1); see C043. ecfr.gov |
| R027-P1-C030 | The standard existing-account notice period is 30 days after taking adverse action. First determine that the action is adverse action under §1002.2(c), including its current-default, agreed-change, and other exclusions. | S008 §1002.9(a)(1)(iii); S006 §1002.2(c). ecfr.gov +1 |
| R027-P1-C031 | The standard counteroffer provision requires adverse-action notification within 90 days after notifying the applicant of the counteroffer when the applicant neither expressly accepts nor uses it. This provision does not require keeping the offer open for 90 days. A compliant combined notice can eliminate a second notice. | S008 §1002.9(a)(1)(iv), comments 9(a)(1)-5–6. ecfr.gov +1 |
| R027-P1-C032 | The ordinary adverse-action notice is written and includes the action, creditor’s name/address, the ECOA statement, the responsible federal agency’s name/address, and either specific reasons or the prescribed right-to-request disclosure. Business and small-volume alternatives qualify this ordinary format. | S008 §1002.9(a)(2), (b)(1), (a)(3), (d). ecfr.gov |
| R027-P1-C033 | Under the ordinary right-to-request route, a request made within 60 days of notification invokes a reasons statement within 30 days after the creditor receives the request. The disclosure identifies the person/office and its address/telephone number. Making the request and the creditor receiving it are distinct events. | S001 §1691(d)(2)(B); S008 §1002.9(a)(2)(ii); S012 C-5/C-8. uscode.house.gov +2 |
| R027-P1-C034 | Where reasons are provided orally under the ordinary route, the applicant must also be told of the right to written confirmation within 30 days after the creditor receives the applicant’s written confirmation request. This is a separate request/response mechanism. The special written-response route and §1002.9(d) must be checked separately. | S008 §1002.9(a)(2)(ii); S001 §1691(d)(2)(B), (5). ecfr.gov +1 |
| R027-P1-C035 | For the smaller-business route, the statement of action taken may be oral or written. That permission does not by itself convert every other required component into an oral disclosure. Paragraphs (a)(1)–(2) otherwise apply subject to the specified exceptions. | S008 §1002.9(a)(3)(i)(A). ecfr.gov |
| R027-P1-C036 | The smaller-business creditor may give the right-to-reasons disclosure at application, instead of at adverse action, if it contains the §1002.9(a)(2)(ii) information and the §1002.9(b)(1) ECOA notice. This is optional and does not itself communicate the later credit decision. | S008 §1002.9(a)(3)(i)(B); S012 C-8. ecfr.gov +1 |
| R027-P1-C037 | For a smaller-business application made entirely by telephone, an oral statement of action and the right to reasons satisfies §1002.9(a)(3)(i). The general telephone-denial comment otherwise calls for obtaining an address to send a required written notice; its rule must not erase this express business exception. | S008 §1002.9(a)(3)(i)(C), comment 9(a)(1)-7. ecfr.gov +1 |
| R027-P1-C038 | For larger businesses and the trade/factoring/similar categories, action may be communicated orally or in writing within a reasonable time. Comment 9(a)(3)-5 identifies receipt of the completed application as the application-action trigger and deems timing compliant with §1002.9(a)(1) reasonable in all instances. “Reasonable” is not an unlimited waiting period. | S008 §1002.9(a)(3)(ii)(A), comment 9(a)(3)-5. ecfr.gov +1 |
| R027-P1-C039 | Under the larger/trade route, a written request within 60 days of notification requires written adverse-action reasons and the ECOA notice, subject to another applicable express exception. Subparagraph (ii)(B) does not separately restate a response interval. The receipt-based 30-day response is grounded in §1691(d)(2)(B); the Federal Reserve’s explanatory summary expressly applies it to larger businesses. | S008 §1002.9(a)(3)(ii)(B); S001 §1691(d)(2)(B); S019 6-142.3. The summary is supplementary agency explanation, not substituted statutory text. ecfr.gov +2 |
| R027-P1-C040 | A creditor that received no more than 150 applications in the preceding calendar year may satisfy §1002.9, including reasons statements, through oral notifications. The statute uses “did not act on more than” 150 and directs regulatory implementation. The operative regulatory count is received applications, not approved loans, business revenue, or the applicant’s fiscal year. | S008 §1002.9(d); S001 §1691(d)(5). Timing/content duties are not erased merely because oral delivery is permitted. ecfr.gov +1 |
| R027-P1-C041 | The interpretation places notification at delivery or mailing to the applicant’s last known address, or at communication of an oral decision. That is different from the creditor’s later receipt of a reasons request, which starts the response period. No mailbox, holiday, or electronic-delivery convention is inferred here. | S008 comment 9-3; S001 §1691(d)(2)(B). Consumer Financial Protection Bureau +1 |
| R027-P1-C042 | Approval notice can be express or implied; the interpretation gives provision of the requested card, money, property, or services as examples. Approval does not automatically require the adverse-action reasons package. | S008 comment 9(a)(1)-2. Consumer Financial Protection Bureau |
Claim ID · Verified proposition, conditions, and exceptions · Exact authority · 13 data rows
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C043 | Within 30 days after receipt of an application incomplete as to matters the applicant can complete, §1002.9(c)(1) requires either action notice under paragraph (a) or an incompleteness notice under (c)(2). The incompleteness-notice route is optional; doing nothing is not a third alternative supplied by this clause. The preapproval and other express exceptions remain relevant. | S008 §1002.9(c)(1), comment 9(c)(1)-1. The special reasonable-time rule for completed business applications does not itself delete paragraph (c). ecfr.gov +1 |
| R027-P1-C044 | A paragraph (c)(2) notice specifies the needed information, gives a reasonable period to supply it, and explains that failure will end further consideration. The ordinary route is written; §1002.9(d) is a separate oral-notification exception when its predicate is established. | S008 §1002.9(c)(2), (d); S012 C-6. ecfr.gov +1 |
| R027-P1-C045 | Timely supply of the requested information requires action and notice under paragraph (a). Failure to respond within the designated period ends further obligation under §1002.9 under this route. Late submission may be treated as requiring a new application. These are not conclusions about contract, other law, or actual completeness. | S008 §1002.9(c)(2), comment 9(c)(2)-1. ecfr.gov +1 |
| R027-P1-C046 | If applicant-supplied information is missing and there is insufficient information to decide, incompleteness may be the denial reason. If enough information exists to make the adverse decision for another reason, the creditor must give that actual reason or the prescribed right-to-request disclosure; it cannot substitute “incomplete application.” | S008 comments 9(a)(1)-3–4. Consumer Financial Protection Bureau |
| R027-P1-C047 | An oral request for missing information is permitted. If the application remains incomplete, the creditor must provide the notice required by §1002.9(c)(1) within its period; an ordinary oral inquiry is not itself a perpetual substitute for the required notice. | S008 §1002.9(c)(3), comment 9(c)(3)-1. Applicable §1002.9(d) remains separate. ecfr.gov +1 |
| R027-P1-C048 | The official interpretation excepts preapprovals constituting applications under §1002.2(f) from the requirement to provide an incompleteness notice. This is not an exception from all application or adverse-action duties. | S008 comment 9(c)(1)-1; S006 comment 2(f)-5. Consumer Financial Protection Bureau +1 |
| R027-P1-C049 | Express acceptance or use of the counteroffered credit satisfies the counteroffer condition in the adverse-action definition. If a compliant adverse-action notice was combined with the counteroffer, a second adverse-action notice is unnecessary upon nonacceptance. The offer’s expiration and the notification deadline remain separate concepts. | S006 §1002.2(c)(1)(i); S008 comments 9(a)(1)-5–6; S012 C-4. ecfr.gov +2 |
| R027-P1-C050 | An expressly withdrawn application does not require §1002.9 notification, although record-retention obligations remain. Silence or missing information is not automatically an express withdrawal. | S008 comment 9-2; S010 §1002.12(b)(3). Consumer Financial Protection Bureau +1 |
| R027-P1-C051 | The approved-application withdrawal rule is narrow: the parties contemplated that the applicant would inquire about status, the creditor approved, and the applicant did not inquire within 30 days after applying. The creditor may then treat it as withdrawn and need not comply with (a)(1). | S008 §1002.9(e). ecfr.gov |
| R027-P1-C052 | For multiple applicants, one notification is sufficient, but it must go to the primary applicant if one is readily apparent. This provision does not decide who legally counts as an applicant or give a guarantor an independently established notice status. | S008 §1002.9(f); S006 §1002.2(e). ecfr.gov +1 |
| R027-P1-C053 | When an application is submitted on an applicant’s behalf to multiple creditors, the others need not notify if the applicant expressly accepts or uses one creditor’s offered credit. If no offer is made, or none is expressly accepted/used, each creditor taking adverse action must comply directly or through a third party. Mere approval is not the stated acceptance/use predicate. | S008 §1002.9(g); S001 §1691(d)(4). ecfr.gov +1 |
| R027-P1-C054 | A combined third-party notice identifies each creditor, including names/addresses under the interpretation, and either gives the request-right disclosure or clearly attributes each creditor’s principal reasons. Where several federal enforcement agencies are involved, the interpretation permits listing any one of them for that combined notice. | S008 §1002.9(g), comments 9(g)-1–2. Consumer Financial Protection Bureau |
| R027-P1-C055 | The third-party interpretation supplies a conditional protection when the creditor accurately and timely supplies needed notice information and maintains reasonable procedures adapted to prevent violations. Delegation alone is not the condition. No actual liability assessment is made here. | S008 comment 9(g)-3. Consumer Financial Protection Bureau |
Claim ID · Verified proposition, conditions, and exceptions · Exact authority · 24 data rows
| Claim ID | Verified proposition, conditions, and exceptions | Exact authority |
|---|---|---|
| R027-P1-C056 | Reasons must be specific and identify the principal reasons actually supporting the adverse action. A generic reference to internal standards/policies or failure to attain a qualifying creditor score is insufficient. The ECOA nondiscrimination statement is not itself a statement of denial reasons. | S001 §1691(d)(3); S008 §1002.9(b)(1)–(2), comments 9(b)(2)-1–2. uscode.house.gov +2 |
| R027-P1-C057 | In credit scoring, disclosed reasons must correspond to actual scored factors, and a principal adverse factor cannot simply be omitted. The comment does not require explaining the factor’s predictive relationship to creditworthiness. | S008 comments 9(b)(2)-2–4. Consumer Financial Protection Bureau |
| R027-P1-C058 | Judgmental reasons concern factors actually reviewed by the decision-maker. In a combined system, reasons come from the failed component; where the described intermediate-score/judgmental process is used, reasons may need to come from both components. Actual system operation remains unknown. | S008 comments 9(b)(2)-6–7, including all examples. Consumer Financial Protection Bureau |
| R027-P1-C059 | The interpretation does not impose one method for selecting scoring reasons or a fixed required number. Its observation that more than four reasons is unlikely to help is not a four-reason legal cap. An automatic-denial factor must be disclosed when it caused the denial. | S008 comments 9(b)(2)-1, -5, -8. No scoring arithmetic performed. Consumer Financial Protection Bureau |
| R027-P1-C060 | A notice that a consumer report was used, or a list of factors affecting a consumer credit score, does not by itself satisfy ECOA’s requirement to explain the creditor’s actual adverse-action reasons. This is the narrow FCRA cross-reference; actual FCRA coverage and notices remain held. | S008 comment 9(b)(2)-9; S012 Appendix C paragraph 2. Consumer Financial Protection Bureau +1 |
| R027-P1-C061 | Written Regulation B disclosures must be clear/conspicuous and, subject to specified exceptions not including §1002.9, in a retainable form. Required writings may be electronic subject to applicable E-Sign requirements. The special application-accompanying exceptions listed in §1002.4(d)(2) do not list §1002.9. | S009 §1002.4(d)(1)–(2). No actual electronic-delivery compliance finding. ecfr.gov |
| R027-P1-C062 | A creditor must take written applications for the dwelling-related credit covered by §1002.13(a). Disclosures may be in another language if available in English on request. Neither provision creates a mandatory nationwide business-credit application form. | S009 §1002.4(c), (e); S011 §1002.13(a). ecfr.gov +1 |
| R027-P1-C063 | Under §1002.12(b)(1), the ordinary business-credit retention period is 12 months after notification of action or incompleteness, subject to (b)(5) and Subpart B. Covered material includes the application and retained evaluation information, written action/reasons notices or any notation/memorandum made for oral notices, and written allegations of violations. | S010 §1002.12(b)(1)(i)–(iii). The “any notation made” language is not rewritten as a duty to create a verbatim transcript. ecfr.gov |
| R027-P1-C064 | Existing-account records use the notice-of-adverse-action trigger under (b)(2). Applications with no §1002.9 notice duty use the creditor’s receipt-of-application trigger under (b)(3). Both contain business-credit and other qualifications. The ordinary consumer 25-month period must not silently replace the business provision. | S010 §1002.12(b)(2)–(3), comment 12(b)(3)-1. ecfr.gov +1 |
| R027-P1-C065 | For the larger-business/trade/factoring/similar category, (b)(5) requires records for at least 60 days after action notification, except as otherwise provided in Subpart B. A written request within that period for reasons or for retention invokes the provision’s 12-month retention requirement. A retention request is not automatically a reasons request. | S010 §1002.12(b)(5). Full retention duties and any actual destruction date remain held. ecfr.gov |
| R027-P1-C066 | The specified actual-notice/service predicates for investigations or enforcement proceedings extend retention until final disposition unless the agency/court permits earlier release. The ordinary period’s expiration therefore is not universal permission to destroy. | S010 §1002.12(b)(4). No proceeding or docket was queried. ecfr.gov |
| R027-P1-C067 | Section 1002.13’s monitoring collection applies to the defined principal-residence purchase/refinance setting; its interpretation limits it to natural-person applications. A dwelling as collateral alone does not establish that section’s purpose predicate. This is separate from the business-notice revenue classification and section 1071. | S011 §1002.13(a), comments 13(a)-1–5. ecfr.gov +1 |
| R027-P1-C068 | Appendix C permits creditor-designed notices and use of all or parts of the samples. Its compliance statements require proper use. The bounded read establishes optional/illustrative samples for this framework, not a universally mandatory single national notice form. | S012 Appendix C paragraphs 1, 3–5. Consumer Financial Protection Bureau +1 |
| R027-P1-C069 | C-4 illustrates a counteroffer with adverse action/reasons; C-5 the later-request alternative; C-6 incompleteness; C-7 business adverse action/reasons; C-8 the business right-to-reasons disclosure at application. C-8 includes the 60-day request and receipt-based 30-day response language. | S012 Forms C-4 through C-8, bounds in source register. Consumer Financial Protection Bureau +1 |
| R027-P1-C070 | Checking the closest listed reason is inadequate if it was not an actual factor. Appendix C directs modification or an appropriate explanation where necessary; the sample’s vocabulary cannot replace the real principal reason. | S012 paragraphs 3–4; S008 comment 9(b)(2)-2. Consumer Financial Protection Bureau +1 |
| R027-P1-C071 | The ECOA notice must be substantially similar to §1002.9(b)(1) and identify the appropriate federal notice agency under Appendix A. Appendix A does not purport to describe every agency’s enforcement authority. No actual creditor’s agency can be selected from unknown status facts. | S008 §1002.9(b)(1), comment 9(b)(1)-1; S013 introduction. ecfr.gov +2 |
| R027-P1-C072 | Federal law preserves state credit-discrimination protections except for inconsistency; greater protection is not treated as inconsistent under the stated standards. A state-regulated class exemption requires the statutory/regulatory determination and enforcement predicates. No particular state exemption is established here. | S004 §1691d(f)–(g); S014 §1002.11(a), (e). uscode.house.gov +1 |
| R027-P1-C073 | An inadvertent error requires an unintentional mechanical/electronic/clerical error despite reasonably adapted preventive procedures. Section 1002.16(c) addresses specified failures, including §1002.9, and requires notice errors to be corrected as soon as possible after discovery. An error of legal judgment is not the defined inadvertent error. | S006 §1002.2(s); S015 §1002.16(c), comment 16(c)-1. ecfr.gov +2 |
| R027-P1-C074 | A special-purpose-program eligibility denial is not automatically a notice exemption. Current comment 8(b)-1 says that a creditor rejecting an application because program eligibility requirements are unmet must nevertheless notify as §1002.9 requires. Program validity and discrimination merits remain held. | S016 current comment 8(b)-1; S001 §1691(c). federalregister.gov +1 |
| R027-P1-C075 | Source currency is bounded by the retrieved bodies: the four ECOA statutory sections state Oct. 20, 2026 legislative currency, and the principal notification eCFR page states Oct. 26. These statements are not a full later-law or judicial-history audit. | S001–S004; S008; S020. uscode.house.gov +3 |
| R027-P1-C076 | The two examined 2026 final rules have effective dates already reached, but their amendment directions do not replace §1002.9. The April rule also preserves the specific special-purpose denial-notice instruction identified in C074. | S016 Dates; instructions 1–6; S017 Dates; instructions 1–13. govinfo.gov +3 |
| R027-P1-C077 | The 2023 amendment removed an obsolete §1002.9(b)(1) sentence allowing old agency-contact information and revised Appendix A. Its general effective date was Apr. 19, 2023; the Appendix A mandatory compliance date was Mar. 20, 2024. | S018 Dates, IV.A, amendment instructions 3–4. federalregister.gov +1 |
| R027-P1-C078 | Section 1071 data/reporting classifications are not substitutes for §1002.9 classifications, even where numerical thresholds coincide. The May 2026 reporting interpretation expressly says its action-reporting rule does not impair §701(d), §1002.9, or other Subpart A provisions. | S017 comment 109(a)(3)-1.i; S008 §1002.9(a)(3). federalregister.gov +1 |
| R027-P1-C079 | The official scope interpretation generally excludes lending activity outside the United States and includes activity within the United States, Puerto Rico, and U.S. territories/possessions regardless of citizenship. No actual location, cross-border transaction, or separate territorial/foreign-law result is established. | S005 comment 1(a)-2. Consumer Financial Protection Bureau |
Issue · Ordinary §1002.9(a)(1)–(2) route, available by election for business credit · Smaller-business route: §1002.9(a)(3)(i) · 12 data rows
| Issue | Ordinary §1002.9(a)(1)–(2) route, available by election for business credit | Smaller-business route: §1002.9(a)(3)(i) | Larger-business/trade/factoring/similar route: §1002.9(a)(3)(ii) |
|---|---|---|---|
| Entry condition | Creditor follows ordinary notification provisions; business creditors may elect this route. | Preceding-fiscal-year gross revenues at or below $1 million, subject to product exclusions and comment 9(a)(3)-1. | Revenues above $1 million or listed product classification. |
| Completed-application action | 30 days after receipt of completed application. | Same incorporated timing. | Reasonable time after receipt of completed application; ordinary timing is deemed reasonable. |
| Adverse-action delivery | Written ordinary notice. | Action statement may be oral or written; other components follow the incorporated rule and express exceptions. | Action may be oral or written. |
| Reasons furnished with notice | Specific written reasons can satisfy the ordinary alternative. | Available under incorporated rules. | Written reasons/ECOA notice must be supplied on the prescribed timely written request; voluntary fuller disclosure remains possible. |
| Right-to-request alternative | Required disclosure accompanies adverse action when this alternative is used. | Disclosure may instead be provided at application if required content and ECOA notice are included. | Paragraph (ii) does not independently prescribe the ordinary upfront right-to-request disclosure. Preserve statutory framework and actual elected procedure. |
| Request condition | Request within 60 days of notification; this ordinary provision does not demand that the initial request be written. | Incorporated ordinary request mechanics, except where another express provision controls. | Written request within 60 days of notification. |
| Response interval | 30 days after creditor receives the request. | Same. | Statutory receipt-based 30 days, with the textual distinction explained in C039. |
| Oral reasons | Permitted through the ordinary request route with the written-confirmation-right disclosure. | Same incorporated mechanism; telephone and small-volume exceptions require separate checking. | Required response under (ii)(B) is written, subject to a separately applicable express exception such as (d). |
| Entirely telephone application | General telephone-denial interpretation applies where a writing is required. | Express oral action/right-to-reasons alternative. | Already permits oral action; request-response conditions remain separate. |
| Incomplete application | §1002.9(c) alternatives and content apply, subject to express exceptions. | Same. | Do not convert the reasonable-time rule for completed applications into deletion of §1002.9(c). |
| Counteroffer | Standard 90-day provision, acceptance/use condition, and combined-notice alternative. | Incorporated standard provision. | Apply special timing and comment 9(a)(3)-5; ordinary timing is an expressly recognized reasonable route. |
| Record-retention connection | Actual business classification still matters under §1002.12; notice-route election is not a complete retention analysis. | Ordinary business application period, with qualifications. | Special (b)(5) period and timely written-request extension, with other holds preserved. |
Event · Whose event matters · Provision-level significance · 9 data rows
| Event | Whose event matters | Provision-level significance |
|---|---|---|
| Receipt of an application | Creditor’s receipt | Can start §1002.9(c)(1) for applicant-completable incompleteness. |
| Completion | Creditor possesses the regularly required information, with reasonable diligence | Starts the completed-application action framework. |
| Adverse action | Creditor’s decision/action | Relevant to incomplete-application and existing-account provisions. |
| Notification | Creditor delivers/mails notice or communicates oral decision | Relevant to the reasons-request period and counteroffer rule. |
| Making a reasons request | Applicant | Must satisfy the applicable form and timeliness condition. |
| Receipt of that request | Creditor | Starts the response interval. |
| Request for written confirmation of oral reasons | Applicant’s written request received by creditor | Separate 30-day confirmation mechanism. |
| Counteroffer acceptance/use | Applicant | Can change whether adverse-action notice remains required. |
| Information supplied after an incompleteness notice | Applicant’s response within the designated period | Determines the next paragraph (a) obligation or permitted closure under paragraph (c). |
Form · Classification and function · Material content actually read · 5 data rows
| Form | Classification and function | Material content actually read | What proper use still requires |
|---|---|---|---|
| C-4 | Optional sample combining adverse action, reasons, and counteroffer. | Denial of requested terms, reasons, alternative terms, an acceptance period/address, ECOA language, and consumer-report-related portions. | Actual principal reasons; appropriate counteroffer terms; all applicable notice content. It does not establish that an offer must remain open for 90 days. |
| C-5 | Optional sample of adverse action with a right to request specific reasons. | Action statement, contact office, 60-day request period, receipt-based 30-day response, ECOA language, and consumer-report portions. | Correct route, accurate contact information, applicable content, and actual response compliance. |
| C-6 | Optional sample incompleteness notice. | Information needed; date by which it must be received; consequence of no timely response; creditor contact fields. | Applicant-completable missing information, reasonable response period, correct notice timing, and appropriate next action. |
| C-7 | Optional business-credit adverse-action/reasons sample. | Creditor fields, denial statement, reasons space, illustrative collateral/earnings/payment-history categories, and ECOA notice. | Reasons must describe factors actually used. The examples do not establish a valid reason in an unknown application. |
| C-8 | Optional business-credit right-to-reasons disclosure given at application. | Creditor fields, right to written specific reasons, request contact, 60-day request period after decision notification, 30-day response after receipt, and ECOA notice. | Early-disclosure conditions under §1002.9(a)(3)(i)(B); later action notification; appropriate request/response handling. |
Example family · What the official example establishes · Limit · 10 data rows
| Example family | What the official example establishes | Limit |
|---|---|---|
| Inquiry/prequalification | Explaining terms can remain an inquiry; evaluating and communicating rejection can turn the exchange into an application disposition. | Published examples are consumer examples; no actual business exchange was reviewed. |
| Written-form policy versus oral practice | Actual decision practices count as application procedures. | Does not decide an unidentified creditor’s practices. |
| Missing information | Insufficient decision information can support an incompleteness denial; sufficient information supporting another denial requires the actual reason. | No invented missing documents or underwriting facts. |
| Counteroffer | A combined compliant adverse-action/counteroffer notice can avoid a second notice. | No mandated 90-day offer duration. |
| Trade credit | Supplier financing of its sale differs from financial-institution financing of the same goods. | “Equipment loan” alone does not classify the transaction. |
| Factoring | Receivables purchase differs from credit incident to the arrangement. | No actual contract-characterization conclusion. |
| Current versus past default | Current default on the affected account differs from historical default as a denial reason. | No account status is inferred. |
| Terms versus type | Rejecting requested terms of an offered type can be adverse action. | No obligation to offer every credit type. |
| Scored/judgmental reasons | Reasons follow the factors and decision component actually responsible for the adverse result. | No score reconstruction or model validation. |
| Listed form reason versus actual reason | Selecting an approximate checklist reason does not replace accurate disclosure. | No actual notice deemed compliant or defective. |
Branch ID / status · Branch and verified rule · Claim/source links · 30 data rows
| Branch ID / status | Branch and verified rule | Claim/source links | Missing evidence | Adverse inference to avoid | Exact permissible next public-law inquiry |
|---|---|---|---|---|---|
| R027-P1-E001 — A/H | Consumer/business purpose uncertain. Apply primary purpose, including mixed use; a business label alone does not settle it. | C008; S006 §1002.2(g)–(h), comment 2(g)-1. | Purpose, use, applicant statement. | “A business name makes every transaction business credit.” | Examine published interpretations of §1002.2(g) for the abstract mixed-purpose issue; retain actual purpose as unknown. |
| E002 — A/H | Applicant/creditor status unknown. Apply the relevant statutory and regulatory definitions and provision-specific expansions. | C002–C004; S002; S006 §1002.2(e), (l). | Requester/obligor roles; decision participation; assignment role. | “Every intermediary or guarantor automatically owes/receives every notice.” | Compare the definitions and their express cross-reference limits; guarantor litigation/signature issues remain held. |
| E003 — A/H | Application versus inquiry. Actual procedures and the creditor’s evaluative response matter. | C005, C009; S006 comments 2(f)-1–4; S008 comment 9-5. | Exchange content and actual procedures. | “No signed form means no application.” | Read the official inquiry and oral-practice examples without investigating a party. |
| E004 — A/H | Completed versus incomplete. Completion concerns received, regularly considered information; diligence remains required. | C006; S006 §1002.2(f), comment 2(f)-6. | Regular requirements, missing material, receipt and diligence facts. | “Applicant submission proves completion,” or “creditor can delay completion indefinitely.” | Examine necessary approvals/reports and reasonable-diligence language at the generic level. |
| E005 — A/H | Incompleteness notice versus adverse action. Paragraph (c) supplies alternative routes with different content. | C043–C047; S008 §1002.9(c), comments 9(a)(1)-3–4. | Missing information, sufficiency for decision, notice selected. | “A request for more information is always a denial,” or the reverse. | Compare (c)(1)–(3) with the two incompleteness-denial comments. |
| E006 — A/H | Threshold/revenue period unestablished. Use gross revenue in the preceding fiscal year and recognized special classifications. | C023–C024; S008 §1002.9(a)(3), comment 9(a)(3)-1. | Revenue assertion, correct fiscal period, applicant capacity. | “Current-month sales or a calendar-year figure necessarily answers the test.” | Investigate only published interpretations of the §1002.9 revenue predicate; do not import another regime’s definition. |
| E007 — A/H | Revenue versus loan-amount confusion. The notice threshold measures business revenue, not requested credit or collateral. | C023, C078; S008 §1002.9(a)(3). | Correctly labeled measurement and period. | “A loan below $1 million necessarily gets the smaller-business route.” | Compare the exact noun and period in (a)(3)(i)–(ii); no arithmetic is needed. |
| E008 — P/H | Trade/factoring/similar category unestablished. Supplier credit and incidental factoring credit have specific guidance; “similar” is not exhaustively resolved by the read comments. | C025–C026; S008 comments 9(a)(3)-2–3. | Transaction structure; deferred-payment right; actual category. | “Anything financing inventory is trade credit,” or “everything called factoring is outside ECOA.” | Search published agency interpretations of the abstract “other similar types” classification; contract characterization remains held. |
| E009 — A/H | Standard versus special-business procedure. A qualifying creditor may elect stricter standard or smaller-business treatment. | C027–C039; S008 comment 9(a)(3)-4. | Classification and actual compliance route. | “The special procedure is mandatory,” or “it is a complete exemption.” | Compare permissible elections with each route’s content and timing. |
| E010 — A/H | Oral versus written notification. Separate action statement, request-right disclosure, reasons, and written confirmation. | C032–C040, C061; S008 §1002.9(a)(2)–(3), (d); S009 §1002.4(d). | Application channel, component content, volume predicate. | “One permitted oral component makes the whole process oral.” | Apply each express oral alternative to the particular notice component, abstractly. |
| E011 — A/H | Reasons statement versus right-to-request. These are alternative compliance mechanisms, not interchangeable documents without conditions. | C032–C036, C056; S008 §1002.9(a)(2), (b)(2). | Whether reasons were supplied or the prescribed right disclosed. | “An ECOA rights paragraph explains the denial.” | Compare the required elements of (a)(2)(i), (a)(2)(ii), and (b)(1)–(2). |
| E012 — A/H | Actual request versus elapsed period. A request-dependent obligation requires the relevant request, including writing where specified. | C033, C039; S001 §1691(d)(2)(B); S008 §1002.9(a)(3)(ii)(B). | Existence, form, and timeliness of request. | “Waiting 60 days proves a request was made,” or proves waiver of every possible right. | Examine the statutory request condition and the special-business writing requirement; infer no request. |
| E013 — A/H | Request receipt versus response. Request timing and creditor receipt are separate; receipt starts the response interval. | C033–C034, C039, C041. | Notification event, request event, receipt, response. | “The response clock starts at denial,” or automatically at mailing a request. | Read §1691(d)(2)(B) and §1002.9(a)(2)(ii) together; any delivery convention needs a separately established authority. |
| E014 — A/H | Counteroffer accepted versus unaccepted. Express acceptance/use and a combined notice affect subsequent notice duties. | C011, C031, C049; S008 comments 9(a)(1)-5–6. | Acceptance/use, notification, combined content, offer expiration. | “Counteroffer issuance equals acceptance,” or “90 days is the offer’s required life.” | Compare the definition, timing clause, and C-4’s function. |
| E015 — A/H | Third-party/multiple-creditor notice. Acceptance/use of one offer can remove others’ action notices; otherwise each adverse creditor must comply. | C053–C055; S008 §1002.9(g), comments 9(g)-1–3. | Submission roles, decisions, acceptance/use, attribution. | “One approval or one broker letter necessarily excuses everyone.” | Examine the acceptance/use condition and combined-notice attribution requirements. |
| E016 — A/H | Multiple applicants. One notice suffices, directed to an apparent primary applicant. | C004, C052; S008 §1002.9(f). | Applicant status and apparent primary applicant. | “Every signer needs a duplicate,” or “any recipient always suffices.” | Compare §1002.9(f) with the applicant definition; do not adjudicate guarantor status. |
| E017 — A/H | Existing account versus default exception. Determine the action and current status of that same account. | C011–C014, C030. | Action, account relationship, current versus past status. | “Any prior missed payment eliminates all notice rights.” | Read §1002.2(c)(2)(ii) and its current/past-default comment. |
| E018 — A/H | Actual notice content unavailable. Required fields can be identified, but compliance cannot be found without the notice and its route. | C032, C056, C061, C071. | Actual text, delivery form, reason source, appropriate agency. | “A document titled adverse-action notice is compliant,” or defective merely because unavailable. | Compare blank required fields with §1002.9; public law cannot supply unseen notice content. |
| E019 — A/H | Model form versus compliance. Optional samples require proper adaptation and actual reasons. | C068–C070; S012 paragraphs 3–5. | Actual completed content and use. | “Using C-7/C-8 guarantees compliance.” | Examine Appendix C’s proper-use and modification instructions. |
| E020 — A/H | Notice compliance versus discrimination merits. The procedural and substantive inquiries remain distinct. | C001, C014, C074; S001 §1691(a), (c), (d). | Underwriting facts, protected-basis facts, comparative evidence. | “A timely notice proves nondiscrimination,” or “a notice defect establishes every merits element.” | Keep the inquiry confined to procedural elements; merits and remedies remain held. |
| E021 — A/H | State/contract/FCRA overlay. Federal notice duties do not determine all other rights or obligations. | C060, C072; S004 §1691d(f)–(g); S014 §1002.11. | Jurisdiction, applicable exemption, contract, report use. | “ECOA compliance resolves every notice or contract issue.” | Examine federal preservation/exemption language only; state, contract, and full FCRA investigations remain held. |
| E022 — A/H | Startup, sole proprietor, or individual business applicant. The official comment supplies distinct routing instructions. | C024; S008 comment 9(a)(3)-1. | Capacity, startup character, revenue statement, product category. | “No prior revenue automatically removes notice protection.” | Apply the comment’s separate categories without inventing revenue. |
| E023 — A/H | Express withdrawal versus special approved-application withdrawal. The latter requires all stated predicates and is optional. | C050–C051; S008 comment 9-2; §1002.9(e). | Express withdrawal or approval/status-inquiry arrangement. | “Silence always withdraws an application.” | Compare express withdrawal, (e), and incompleteness closure separately. |
| E024 — A/H | Utilities/securities/incidental/government exceptions. Each has its own definition and exception list. | C015–C018; S007 §1002.3(a)–(d). | Qualifying category predicates. | “Every nonconsumer transaction is exempt,” or “government funding means government credit.” | Read the complete definition and exception list for the abstract class, without identifying a provider. |
| E025 — A/H | Small-volume creditor. The test is prior-calendar-year received applications, separate from business revenue. | C040; S008 §1002.9(d); S001 §1691(d)(5). | Application count and correct year. | “A small loan or small business proves the creditor qualifies.” | Compare statute and implementing count language; retain actual volume as unknown. |
| E026 — A/H | Retained content and special request. Reasons requests and retention-only requests have different purposes; additional retention predicates remain. | C021, C063–C066; S010 §1002.12(b)(1)–(5). | Record type, notice event, written request, other holds. | “60 days permits destruction of everything,” or “retention request automatically requests reasons.” | Reconcile only the specified application-record clauses; full retention schedule remains held. |
| E027 — A/H | Preapproval exception. A qualifying preapproval application has a narrow incompleteness-notice exception. | C010, C048; S006 comment 2(f)-5; S008 comment 9(c)(1)-1. | Program commitment and condition structure. | “Preapproval is never an application,” or “all notices disappear.” | Compare the complete official preapproval example with the narrow exception. |
| E028 — A/H | Inadvertent error. Preventive procedures, unintentional error, and correction duties matter; legal misjudgment is excluded. | C073; S006 §1002.2(s); S015 §1002.16(c). | Nature of error, procedures, discovery, correction. | “Calling a mistake inadvertent establishes the exception.” | Examine the defined error and official examples without making a liability finding. |
| E029 — P/H | Federal geographic or dealer boundary. Location and the §5519 classification can affect the relevant regulatory instrument. | C019, C079; S005; S021. | Activity location and statutory role/function predicates. | “A U.S. applicant or vehicle-related loan automatically resolves scope.” | Update the published §5519 cross-reference if needed; Part 202, foreign, and territorial law remain separate held work. |
| E030 — A/H | Section 1071 versus notification rules. Separate reporting definitions and future compliance dates do not replace §1002.9. | C075–C078; S016–S020. | Which provision an asserted classification actually invokes. | “Removal of a reporting data point abolishes reasons notices.” | Examine the May 2026 rule’s amendment directions and preservation sentence; do not conduct a full Subpart B investigation. |
Field · Blank entry · Governing check · 13 data rows
| Field | Blank entry | Governing check |
|---|---|---|
| Federal source/version used | ______ | S001–S021; C075–C078 |
| Activity within relevant federal geographic scope | ______ | C079 |
| Applicant role established | ______ | C002, C004 |
| Creditor decision-making role established | ______ | C003 |
| Part 1002/§1029 boundary addressed | ______ | C019 |
| Deferred-payment credit element | ______ | C002, C008 |
| Primary purpose and basis for classification | ______ | C008 |
| §1002.3 category, if any, and exact predicates | ______ | C015–C018 |
| Business capacity: startup / proprietor / individual / other | ______ | C024 |
| Gross-revenue assertion and preceding fiscal period | ______ | C023–C024 |
| Trade / credit incident to factoring / similar classification | ______ | C025–C026 |
| Notice procedure elected | ______ | C027, C035–C039 |
| Small-volume oral exception predicate | ______ | C040 |
Event · Relevant generic actor · Evidence reference · 16 data rows
| Event | Relevant generic actor | Evidence reference | Event established? |
|---|---|---|---|
| Application received | Creditor | ______ | ______ |
| Information requirements and diligence established | Creditor | ______ | ______ |
| Completed application received | Creditor | ______ | ______ |
| Applicant-completable information missing | Applicant/creditor | ______ | ______ |
| Action taken | Creditor | ______ | ______ |
| Action communicated | Creditor | ______ | ______ |
| Incompleteness notice and reasonable response period | Creditor | ______ | ______ |
| Requested information supplied | Applicant | ______ | ______ |
| Counteroffer communicated | Creditor | ______ | ______ |
| Counteroffer expressly accepted or used | Applicant | ______ | ______ |
| Express withdrawal or §1002.9(e) predicates | Applicant/creditor | ______ | ______ |
| Reasons request made; form of request | Applicant | ______ | ______ |
| Reasons request received | Creditor | ______ | ______ |
| Reasons response provided | Creditor | ______ | ______ |
| Written-confirmation request received | Creditor | ______ | ______ |
| Written confirmation provided | Creditor | ______ | ______ |
Required or conditional element · Blank finding · 14 data rows
| Required or conditional element | Blank finding |
|---|---|
| Correct action statement | ______ |
| Creditor identification/address required by selected route | ______ |
| Applicable ECOA notice | ______ |
| Appropriate federal agency identification/address | ______ |
| Actual principal reasons or compliant request-right disclosure | ______ |
| Correct request contact information | ______ |
| Oral-reasons written-confirmation right, if applicable | ______ |
| Incompleteness information, reasonable period, and consequence | ______ |
| Multiple-applicant recipient condition | ______ |
| Multiple-creditor identities and reason attribution | ______ |
| Clear/conspicuous and retainable writing, if applicable | ______ |
| Applicable electronic-form requirements separately addressed | ______ |
| Model adapted to actual reasons rather than approximate checklist selection | ______ |
| Separate FCRA/state/contract notice questions preserved | ______ |
Field · Blank entry · 9 data rows
| Field | Blank entry |
|---|---|
| Applicable §1002.12 application/account category | ______ |
| Correct retention trigger identified | ______ |
| Reasons request versus retention-only request distinguished | ______ |
| Subpart B and other retention holds preserved | ______ |
| Inadvertent-error predicates and correction, if raised | ______ |
| Unresolved classification issues | ______ |
| Unresolved source/currentness issues | ______ |
| Actual compliance determination authorized and supported? | ______ |
| Independent qualified review completed? | ______ |
Question / material subquestion · Status · Findings and evidence · 19 data rows
| Question / material subquestion | Status | Findings and evidence | Missing evidence or limit | Exact permissible next investigation |
|---|---|---|---|---|
| 1 — ECOA/Regulation B coverage and actors | Answered generically | C001–C008, C019, C079; S001–S006, S021. | Actual roles, purpose, location, and §5519 classification unknown. | Update the relevant published definition/cross-reference if necessary; no party search. |
| 1 — Application, completion, inquiry, adverse action | Answered generically | C005–C014; S006, S008. | Actual procedure, information, and decision facts held. | Compare official application and adverse-action examples with abstract categories only. |
| 1 — Complete necessary statutory clauses and material exceptions | Answered within stated bounds | S001–S004; C015–C022, C072–C074. Complete §1002.3 and §1002.9 read. | No exhaustive grant-of-exemption or judicial-history audit. | Published amendment/exemption instruments only, if a specific public-law issue warrants it. |
| 1 — §1002.12/.13 and adjacent provisions | Answered narrowly; remainder excluded | C061–C067, C073; S009–S011, S015. | Full retention, monitoring, privacy, E-Sign, and section 1071 work held. | Investigate only a necessary notice cross-reference; preserve the broader holds. |
| 2 — Revenue threshold, period, startup/proprietor/individual | Answered generically | C023–C024; E006–E007, E022. | Actual revenue, period, and capacity absent. | Published §1002.9 interpretations; no invented calculation or imported small-business definition. |
| 2 — Trade/factoring/similar classification | Answered for express examples; partial for undefined edge cases | C025–C026; E008. | No exhaustive definition of “other similar types” established. | Search official published classification interpretations for the abstract product issue. |
| 2 — Oral/written, action timing, request and response | Answered with textual distinctions | C028–C041; S001, S008, S019; comparison table. | Actual notification/request/receipt dates unknown; no calendaring conventions selected. | Further official timing interpretation only if needed; no actual deadline finding. |
| 2 — Retainable disclosures and retained records | Answered narrowly | C061, C063–C066, C021. | Record category and other holds unknown. | Focused statutory/regulatory reconciliation; no destruction permission. |
| 2 — Complete relevant §1002.9 comments/examples | Answered | Full comment inventory in S008; C024–C027, C041–C060. | No system, notice, or application evidence. | No further source expansion needed to state the generic framework. |
| 3 — Incomplete application versus action notice | Answered | C029, C043–C048; E004–E005, E027. | Missing-information and sufficiency predicates unknown. | Official paragraph (c) and preapproval interpretations only. |
| 3 — Counteroffers/acceptance/expiration | Answered | C011, C031, C049; E014. | No counteroffer or acceptance facts. | Examine the combined-notice provision and special-route timing where necessary. |
| 3 — Multiple applicants and third parties | Answered | C052–C055; E015–E016. | Actual primary applicant, creditor decisions, and acceptance/use absent. | Definitions and published multiple-creditor interpretations only. |
| 3 — Withdrawal and existing accounts | Answered | C014, C030, C050–C051; E017, E023. | No withdrawal, approval, status-inquiry, or default facts. | Distinguish the express regulatory predicates; no status search. |
| 4 — Relevant model notices/instructions | Answered within complete C-4–C-8 text bounds | C068–C071; S012–S013; Section 4. | No actual notice; C-1–C-3 not fully audited; no form pixels inspected. | Additional official sample only if a distinct notice function becomes necessary. |
| 4 — Mandatory versus optional form and edition | Answered, bounded | Appendix C paragraph 5; current online codified edition; S018 contact amendment. | No universal statement about every program or jurisdiction. | A separately authorized program-specific public-law form inquiry, if needed. |
| 5 — Comparison and blank audit worksheet | Completed | Sections 3 and 6. | All transaction entries intentionally blank. | None necessary for the blank deliverable. |
| 5 — At least twelve substantive branches | Completed: 30 branches | Section 5, E001–E030, each with rule, claim/source crosswalk, missing evidence, inference to avoid, and public-law next inquiry. | Actual applications remain held throughout. | Only the bounded next inquiry stated in the relevant row. |
| Currentness requirement | Answered with express limits | S016–S020; C075–C078; access date above. | Post-compilation legislation/rules and comprehensive later judicial history not exhaustively audited. | Official current-body/amendment update; no case-record/docket query. |
| Parent A027 dimensions and acceptance | Excluded by instruction | Holds below. | All uninvestigated products, jurisdictions, merits, and operational facts. | Separate authorization and scope would be required for a different component. |
Log ID · Event · Result and treatment · 10 data rows
| Log ID | Event | Result and treatment |
|---|---|---|
| R027-P1-L001 | Initial legacy OLRC URLs: https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1691; https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1691a; https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1691b; https://uscode.house.gov/view.xhtml?edition=prelim&num=0&req=granuleid%3AUSC-prelim-title15-section1691d. | Returned 404 failures. Recovered through normal public OLRC navigation to S001–S004. Failure was not treated as absence of statutory law. |
| L002 | Initial direct opens of short/current OLRC routes and some versioned routes. | Several returned “not accessible via this tool.” Normal public statute navigation subsequently retrieved the versioned bodies used in S002–S004. No authentication or security bypass. |
| L003 | https://uscode.house.gov/us/usc/t12/s5519/. | Direct retrieval failed. An official indexed version through Oct. 15 was opened and read as S021; that currency limit remains explicit. |
| L004 | FDIC examination manual: https://www.fdic.gov/consumer-compliance-examination-manual/v-7-equal-credit-opportunity-act-ecoa. | Search returned text, but direct opening returned 403 Forbidden. No claim of full-body review; it is not a necessary foundation for the claims. |
| L005 | CFPB interactive Regulation B pages. | Retrieved successfully. Publisher’s update-lag notice prompted comparison with eCFR and the 2026 final-rule amendment instructions. |
| L006 | eCFR sections and Appendix C. | Relevant bodies retrieved. Currency stamps varied by retrieved snapshot, as recorded. These are authoritative online presentations but are not described here as official legal editions of the CFR. |
| L007 | Federal Register HTML and govinfo PDFs. | Selected final-rule dates and operative amendment bounds read. Parsed PDF text was used; no pixel inspection and no full-PDF read claim. |
| L008 | CFPB October 2015 examination PDF. | Successful retrieval exposed the reference-only cover. Classified historical and excluded as a current-law foundation. |
| L009 | Long or initially clipped search/open outputs. | Targeted follow-up opens supplied the material operative clauses and complete relevant §1002.9 comments. An initial search excerpt was not treated as a complete read. |
| L010 | Court opinions, dockets, party records, actual forms/applications, and prior reports. | No case-record/docket or party query was performed. No published opinion was needed for the selected generic notice framework. No actual application was obtained or completed. |
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
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Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.
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The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.
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Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.
conditionally reviewed edition and application holds
Original saved Markdown SHA-256: b689f553e44198c91475b8e390f3937a19ca3e6b3b7b043c92aea83b4ee6ce24. Public formatting, private-reference removal and correction annotations are separate from that immutable original.