Replay of a real run — captured 2 Jul 2026
Grounds
Adverse Action Agent
Every step below is a real trace event from the signed run ledger.
sc-grounds
Transcript
I'll start by retrieving the regulation text and the credit report simultaneously — they're independent and I need both before I can map reasons and record.
Both tools returned. Let me review what I have before committing:
Reg B anchor (§ 1002.9(b)(2)): The statement must be specific and indicate the principal reason(s). Saying the applicant "failed to achieve a qualifying score" alone is explicitly insufficient — the underlying credit characteristics that produced the score must be stated.
Decision factors → specific principal reasons (mapped):
| Decision factor | Specific reason (Reg B compliant) |
|---|---|
| Credit score below program minimum | Score of 561 is below the auto program minimum of 600 |
| Recent charge-off and collection | Charge-off of $3,000 (~16 months ago) + collection of $1,200 (~9 months ago) on bureau file |
| Very high revolving utilization (88%) | Revolving balances equal 88% of revolving credit limits |
FCRA score disclosure — grounded on CR-L2:
- Score confirmed: 561
- Bureau key adverse factors: collection (9 mo ago, $1,200), charge-off (16 mo ago, $3,000), revolving utilization at 88%, 6 credit inquiries in the past 6 months
All three factors are confirmed by the bureau report. Recording now.
The decision brief
Reasons recorded. Here is the complete adverse-action determination for application L2:
Adverse Action — Application L2 (Auto Loan) · Decline
Principal Reasons for Adverse Action
(12 CFR 1002.9(b)(2) — statement of specific reasons)
-
Credit score of 561 is below the auto loan program minimum of 600. The applicant's credit score fell in the below-subprime band. A statement that the applicant "did not achieve a qualifying score" alone would be insufficient under Reg B; the underlying credit characteristics driving that score are stated in reasons 2 and 3.
-
A charge-off of $3,000 reported approximately 16 months ago and a collection account of $1,200 reported approximately 9 months ago appear on the applicant's credit report. Both derogatory items are recent and were confirmed on bureau report CR-L2. These are among the most heavily weighted negative factors in any scoring model and in the creditor's underwriting policy.
-
Revolving credit balances are 88% of available revolving credit limits, which is very high. Bureau report CR-L2 confirms 88% revolving utilization. High utilization signals elevated credit risk and is a principal contributor to the score outcome.
FCRA Credit-Score Disclosure
(15 U.S.C. § 1681m — required when adverse action is score-based)
| Field | Value |
|---|---|
| Credit score used | 561 |
| Score range | (to be filled per scoring model's disclosed range) |
| Date score generated | (per CR-L2 pull date) |
| Score source | Bureau report CR-L2 |
Key factors that adversely affected the score (as reported by the bureau):
- Derogatory account — collection reported approximately 9 months ago ($1,200)
- Derogatory account — charge-off reported approximately 16 months ago ($3,000)
- Proportion of revolving balances to revolving credit limits is too high (88%)
- Too many inquiries in the last 6 months (6 inquiries)
Legal Basis
- Reg B notice: 12 CFR 1002.9 — written adverse-action notice with statement of specific reasons required within 30 days of the decision.
- FCRA score disclosure: 15 U.S.C. § 1681m — credit score, key factors, source, and range must accompany the adverse-action notice when a credit score was a factor in the decision.
Notes / Compliance Flags
- ✅ All three principal reasons trace directly to
decision.factors— no invented, softened, or generic reasons used. - ✅ No prohibited basis (race, sex, age, national origin, etc.) appears anywhere in the decision or these reasons.
- ✅ Score (561) confirmed against CR-L2; key bureau factors are grounded in the report's actual tradeline and derogatory data.
- ✅ LTV (126%) appears in
policyBasisbut not indecision.factors; it was not stated as a principal reason per the mandate to derive reasons strictly from the decision's own credit factors. - ⚠️ The notice must also include the ECOA tagline, the supervising agency name/address, and the creditor's name/address per § 1002.9(a)(2) before it is sent to the applicant.