---
title: "List the reasons in a credit file for an adverse-action notice the lawyer will write"
url: "https://ailawframework.com/practice/financial-services-regulation/prepare-explainability-documentation-for-an-ai-fraud-or-credit-model/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A28-B6-3-US"
practice_area: "Financial Services Regulation (AFSL/ASIC/credit)"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# List the reasons in a credit file for an adverse-action notice the lawyer will write

> List factors the credit file actually states, each with the page. Do not rank them and do not draft the notice to the applicant.

Canonical page: https://ailawframework.com/practice/financial-services-regulation/prepare-explainability-documentation-for-an-ai-fraud-or-credit-model/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Financial Services Regulation (AFSL/ASIC/credit)](https://ailawframework.com/practice/financial-services-regulation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List factors the credit file actually states, each with the page. Do not rank them and do not draft the notice to the applicant. |
| What the lawyer must review | 15 U.S.C. § 1691(d) entitles an applicant against whom adverse action is taken to a statement of reasons. A creditor complies by providing the statement in writing as a matter of course, or by giving written notice of the adverse action that discloses the right to a statement of reasons within thirty days after the creditor receives a request made within sixty days after the notice, and the identity of the person or office from which the statement may be obtained. The statement meets the section only if it contains the specific reasons for the action taken. Adverse action, for this subsection, means a denial or revocation of credit, a change in the terms of an existing credit arrangement, or a refusal to grant credit in substantially the amount or on substantially the terms requested. You write the notice. Regulation B was not opened. |
| Written for | United States |
| Applies to | [Prepare explainability documentation for an AI fraud or credit model](https://ailawframework.com/practice/financial-services-regulation/prepare-explainability-documentation-for-an-ai-fraud-or-credit-model.md) |

## Checking plan

- What the AI does: List factors the credit file actually states, each with the page. Do not rank them and do not draft the notice to the applicant.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- A small-creditor verbal-notice path exists in § 1691(d) for a creditor who did not act on more than 150 applications in the preceding calendar year. You decide whether it fits.
- The EEOC's AI page is about employment. Do not use it for a credit decision unless the same tool is also used to make an employment decision.

## Sources

- [15 U.S.C. § 1691, Equal Credit Opportunity Act](https://www.law.cornell.edu/uscode/text/15/1691) (checked 2026-10-22)
- [ABA Model Rule 1.1, Competence](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_1_competence/) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*