Consumer Financial Protection Circular 2023-03: Adverse Action Notification Requirements and Proper Use of Sample Forms

The Consumer Financial Protection Bureau (CFPB) has issued Consumer Financial Protection Circular 2023-03, titled, "Adverse action notification requirements and the proper use of the CFPB's sample forms provided in Regulation B." In this circular, the CFPB responds to the question, "When using artificial intelligence or complex credit models, may creditors rely on the checklist of reasons provided in CFPB sample forms for adverse action notices even when those sample reasons do not accurately or specifically identify the reasons for the adverse action?"