Adverse action and decline notice
How do we produce a mortgage adverse action notice with the actual reasons and the credit score disclosure within 30 days of a decline, counteroffer or withdrawal, from the decision record?
Generate the notice from the decision, not from a code table. When the underwriter declines, counters, or the file is closed for incompleteness or withdrawal, Callvu classifies the action, takes the principal reasons from the decision record, adds the FCRA content where a consumer report was used, produces the notice in the required form, delivers it inside the Reg B period by the consented method, and writes the notice and the delivery to the LOS with the HMDA action taken.
In scopeSimpleCallvu moves: classify, write back
Last updated November 7, 2026.
The problem today
The decline is in the LOS as a status, the reasons are codes picked from a list, and the letter system runs on Fridays.
An underwriter declines a mortgage and picks reasons from a dropdown. A nightly file feeds a letter system. The letter may carry reasons that do not match the credit memo, no credit score, and a date that lands after the 30 days. A counteroffer the borrower never responded to is forgotten, and no notice is sent at all.
Reg B gives 30 days from a completed application to notify the applicant of action taken, with the specific principal reasons or the right to request them; a counteroffer not accepted within the period triggers the notice too. FCRA adds the consumer reporting agency's details, the rights to a free report and to dispute, and the credit score with its key factors. HMDA records the action taken and its date on the register. Fair lending examiners test the reasons against the file.
The notice is a report on a decision. It should be produced from the decision.
How it runs
From the requestto the system of record.
A decision in the LOS results in a decline, a counteroffer, an incompleteness closure, or a withdrawal. Callvu picks up the decision record and opens the notice case with the date the clock started.
- Underwriter
- Records the decision with its reasons in the LOS; confirms reasons in the Decision Desk where the policy requires.
- Loan officer
- Is told the notice went out and can answer the borrower.
- Borrower
- Receives the notice in the consented channel; may request reasons or the report.
- Callvu
- Classifies the action, assembles reasons and FCRA content, produces and delivers the notice, records it with the HMDA action.
Classify the action
The action type sets the notice and the clock: a decline (30 days from the completed application), a counteroffer not accepted (30 days from the offer's expiry, or a combined notice), an incomplete application closed (a notice of incompleteness or an adverse action notice), or a withdrawal (no adverse action notice, but the HMDA action and date). The HMDA action taken code is set.
Assemble the reasons
The principal reasons are taken from the decision record (the underwriter's reasons, the automated underwriting findings, the scoring factors) in order of importance, with the specific wording the lender's policy maps to each. Where a consumer report was used, the agency's details, the score, its range and date, and up to four key factors are added.
Decide: confirm where needed
A decision with recorded reasons that match the record produces the notice by rule. A decision with no recorded reasons, reasons that conflict with the findings, or a fair lending flag goes to the underwriter or compliance in the Decision Desk to confirm before release, with the deadline visible.
Deliver and write back
The notice is delivered by the consented method inside the period, and the notice, its delivery time, the reasons and the FCRA content are written to the LOS with the HMDA action taken and its date. A request for reasons within 60 days is answered from the same record within 30 days.
Where it ends: The borrower received a notice with the actual reasons and the FCRA content inside the 30 days, the LOS holds the notice with its delivery and the HMDA action, and the reasons match the decision the examiner will read. 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 decision in the LOS; the borrower meets the process in the notice.
The back office
Underwriting records reasons once; compliance sees every notice against its deadline and the HMDA action set with it.
The Decision Desk
- A decision without recorded reasons, with conflicting reasons, or flagged by the fair lending policy goes to the underwriter 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 automated underwriting findings and the scoring factors, in order of importance. Not from a dropdown after the fact.
Is a withdrawal an adverse action?
No. The classification sets the HMDA action to withdrawn with its date and sends no adverse action notice.
How is the credit score included?
From the report record: the score, its range and date, the agency and up to four key factors, with the FCRA rights.
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