Adverse action notices
How do we produce adverse action notices with the specific reasons and the credit score disclosure, delivered inside the Reg B deadline, from the decision record?
Generate the notice from the decision, not from a reason file. When an application is declined, countered or closed for incompleteness, Callvu classifies the action, pulls the principal reasons from the decision record, adds the FCRA content where a consumer report was used (the agency, the score and its key factors), produces the notice in the required form, delivers it in the consented channel inside the 30-day period, and records the delivery for the exam.
In scopeSimpleCallvu moves: classify, write back
Last updated November 7, 2026.
The problem today
The notice is produced by a letter system from a nightly file, and the reasons on it are codes nobody chose.
An underwriter declines a loan in the origination system and picks reason codes from a list, or does not. A nightly file feeds a letter system that prints a notice. The specific reasons on the letter may not be the ones the underwriter had, the credit score may be missing, and the date is whenever the batch ran. A counteroffer the applicant did not accept is forgotten, and the 30 days pass.
Reg B requires the notice within 30 days of a completed application (or of the counteroffer not being accepted), with the specific principal reasons or the right to request them. FCRA adds the consumer reporting agency's details, the statement that the agency did not decide, the rights to a free report and to dispute, and the credit score with its key factors when a score was used. The reasons must be the actual reasons, which an examiner tests against the file.
An adverse action notice is also a fair lending record. Reasons that do not match the decision are the first thing a fair lending review finds.
How it runs
From the requestto the system of record.
A credit decision in the loan or card system results in a decline, a counteroffer, an incompleteness closure, or an adverse change on an existing account. Callvu picks up the decision record and opens the notice case with the date the clock started.
- Underwriting
- Makes the decision with its reasons in the system of record; confirms the reasons in the Decision Desk where the policy requires a review.
- Applicant
- Receives the notice in the consented channel and may request reasons or the report.
- Callvu
- Classifies the action, assembles the reasons and FCRA content, produces and delivers the notice inside the deadline, and records it.
Classify the action
The action type sets the notice and the clock: a decline on a completed application (30 days from completion), a counteroffer not accepted (30 days from the offer's expiry), an incomplete application (a notice of incompleteness or an adverse action notice), an adverse change to an existing account, or a business credit decision with its own rules by revenue size.
Assemble the reasons
The principal reasons are taken from the decision record: the underwriter's reasons, the decision rule's factors, or the scoring model's key factors, in the order of importance. Where a consumer report was used, the agency's name and contact details, the score, its range, its date and up to four key factors are added. The notice content is produced in the required form.
Decide
A notice whose reasons match the decision record is released by rule. A decision with no reasons recorded, reasons that do not match the model, or a case the fair lending policy flags goes to underwriting or compliance in the Decision Desk to confirm the reasons before the notice goes.
Deliver and write back
The notice is delivered in the applicant's consented channel inside the period, and the notice as sent, the delivery time, the reasons and the FCRA content are written to the loan or card system with the decision. A request for reasons or for the report is handled from the same record within its period.
Where it ends: The applicant has a notice with the actual reasons and the FCRA content, delivered inside the deadline, and the loan or card system holds the notice with its delivery record. The Decision Trace shows the classification and the reasons' source; the Audit Trace shows the delivery and any later request.
Runtime enforcement
What is enforcedwhile the work runs.
The regulations preloaded in Callvu Studio and the bank's own policies, applied as steps that run, not lines in a binder. A step that breaks a rule does not run, so a completed run was compliant.
The handoff
Between the front doorand the back office.
The front door
The front door is internal: the decision in the loan or card system. The applicant meets the process in the notice.
The back office
Underwriting records reasons once, in the decision; the letter system has nothing to reconstruct. Compliance sees every notice against its deadline.
The Decision Desk
- A decision without recorded reasons, with reasons that do not match the model, or flagged by the fair lending policy goes to underwriting or compliance in the Decision Desk to confirm the reasons before the notice is released.
Proof
In scope.Proof at scale, not one process at a time.
The kind of process Callvu runs in production for customers in this industry. Ask for a reference on this exact process. The results below are the industry's published proof; each claim code links to its record on agents.callvu.com.
Questions
What buyers ask next,answered plainly.
Where do the reasons come from?
From the decision record: the underwriter's reasons, the decision rule's factors or the scoring model's key factors, in order of importance. Not from a code table applied after the fact.
What if a credit score was used?
The score, its range, its date, the agency and up to four key factors are added to the notice from the report record, with the FCRA rights.
How is the 30 days kept?
The clock start is set by the action type at classification, and the notice is delivered and recorded inside it. A case needing confirmation is nudged against the same deadline.
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