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If a loan meets underwriting standards but is a true 'hit' on the OFAC list, what do we use as a denial reason on the adverse action notice?
If you have confirmed with OFAC that you have a 'good hit,' there is no reason not to explain that to the customer. The customer can contact OFAC directly for further information.
Office of Foreign Assets Control (OFAC), U.S. Treasury Department http://www.treas.gov/offices/enforcement/ofac/
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