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A mortgage application may be evaluated with automated tools, manual underwriting, credit models, or a combination. An automated system’s recommendation is not automatically the lender’s final decision: ask what process was used, what information drove the outcome, and whether the lender will consider corrected or updated information. If you receive an adverse-action notice, the explanation requirements apply regardless of the technology involved.

What “automated underwriting” means—and what it does not

Automated underwriting generally means that an electronic system helps evaluate a mortgage application. The CFPB’s ECOA examination procedures ask how lenders use manual underwriting, automated underwriting, credit models, or combinations of those approaches. That recognizes varied practices; it does not establish a single workflow for every lender or borrower.

There is also a narrower regulatory definition. Under the CFPB’s HMDA rule, a covered automated underwriting system (AUS) is an electronic tool developed by a securitizer, federal government insurer, or federal government guarantor to evaluate mortgage applications in circumstances covered by HMDA reporting. Covered lenders report the system name and result when required. This reporting definition is not a complete inventory of every automated tool lenders may use internally, nor does it say that an AUS result is the final lending decision.

A system output may be a recommendation or part of a larger process. The lender’s own documentation is the best way to establish whether the output was advisory, what conditions remained, and who or what made the final decision.

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How to find out who or what decided your application

Ask the lender direct, specific questions. A lender may be able to clarify its process and the information it relied on, but the federal materials described here do not establish a universal right to human reconsideration or manual underwriting after an automated result.

  • Did a person review my application, or was the decision made through an automated process?
  • Was an automated system’s result a recommendation, a condition, or the lender’s final decision?
  • What application information, documentation, or conditions drove the outcome?
  • Is any information missing or potentially inaccurate?
  • Will you consider corrected or updated documentation, a different loan product, or another review?

Ask the lender to distinguish a system recommendation from the final decision rather than assuming the two are the same. Whether another review is available depends on the lender and loan; asking does not guarantee reconsideration or a different result.

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What an adverse-action notice should explain

The CFPB states in Circular 2022-03: “The adverse action notice requirements of ECOA and Regulation B, however, apply equally to all credit decisions, regardless of the technology used to make them.” In other words, using a complex algorithm does not excuse an inadequate explanation.

A creditor must give specific, accurate principal reasons for adverse action. A vague reference to internal standards, a qualifying-score failure, or the complexity of a model is not a substitute for the specific reasons that apply to your application. Read the notice carefully and ask the lender to clarify any reason you do not understand or believe is inaccurate.

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If the denial involved a credit report

The CFPB’s consumer guidance, last reviewed December 31, 2024, explains that a notice for an application rejected based on a credit report should include the numerical credit score used and key factors that affected it, the reporting company’s contact information, and information about your right to obtain a free report from that company within 60 days. It should also explain how to correct errors or add information. Check the notice for the details that apply to your case.

  1. Use the notice to identify the reporting company and request the report within the stated 60-day period.
  2. Compare the report with your records and the lender’s stated reasons. Look for inaccurate, incomplete, or outdated information.
  3. If you find an error, dispute it with both the reporting company and the company that supplied the information.
  4. Ask the lender whether it will consider corrected or updated information. A correction may address one issue, but it does not guarantee approval.

If an appraisal or other valuation affected the decision

Regulation B includes provisions concerning appraisals and other written valuations. The CFPB’s ECOA valuation resource points borrowers to Regulation B § 1002.14 and its official interpretations. Request and review the appraisal or other written valuation documents available for your application, then raise specific factual concerns with the lender.

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Ask the lender how to submit a concern and whether its process or the applicable loan rules allow any further valuation review. The federal materials do not promise a new appraisal, a particular appeal process, or reversal of a lending decision.

Compare your next-step options

What to check Question to ask Why it matters
Decision explanation Does the notice state specific principal reasons, and can the lender explain any unclear reason? Adverse-action explanation requirements apply regardless of decision technology.
Information accuracy Did the lender rely on a credit-report item or application detail that is wrong or incomplete? You can investigate report errors and ask whether corrected information will be considered.
Valuation access Can I review the appraisal or other written valuation, and how do I raise a concern? A valuation may be relevant to the decision; a concern does not guarantee a change.
Further review Will this lender consider another review, updated documents, or a different loan product? Availability depends on the lender and loan; no universal entitlement is established by the sources cited here.
Independent help Is credit or pre-purchase counseling available through a HUD-participating agency near me? A counselor may help with credit or homebuying readiness; local agencies vary in the services they offer.
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Where to get housing-readiness help

HUD-participating housing counseling agencies may offer credit counseling and pre-purchase or homebuyer education. Use HUD’s housing counseling agency search or phone line to find services in your area, and confirm that the agency offers the kind of counseling you need. HUD says counseling cannot be conditioned on your using products or services offered by the agency, its affiliates, or community partners.

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Federal-rule context

The CFPB’s Regulation B resource reports that a final rule issued April 22, 2026 amended provisions concerning disparate impact, discouragement, and special purpose credit programs. The Bureau says the rule removed the regulation’s “effects test,” modified the discouragement prohibition, and changed special-purpose-credit-program provisions. Because these provisions changed recently, consult the current official Regulation B text and final rule for the applicable federal requirements. This overview does not determine whether a particular lending decision complied with the law; state requirements and loan-program-specific procedures may also matter.

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