Compliance
Adverse action notices
What an FCRA adverse-action notice must contain, how Cascades' single-notice and employment flows meet it, the reason vocabulary, and what stays yours.
Warning
This page is not legal advice. It explains what Cascades' adverse-action node does and does not do so you can decide whether it satisfies your obligations. Notice content, timing and delivery requirements vary by use case and by state; consult your counsel and keep your templates under legal review.
When is a notice required?
Under FCRA §615(a), whenever you take an adverse action — deny a rental application, decline credit, refuse employment, change terms unfavourably — based in whole or in part on information in a consumer report, you must tell the consumer. The notice must include, at minimum:
- that adverse action was taken, and the name, address and telephone number of the consumer reporting agency that supplied the report;
- a statement that the agency did not make the decision and cannot explain why it was taken;
- the consumer's right to obtain a free copy of the report from the agency within 60 days, and to dispute the accuracy or completeness of any information in it;
- for credit decisions, the credit score used and the key factors that adversely affected it (the risk-based pricing / score-disclosure rules), where a score was used.
For employment, §604(b)(3) adds a two-step sequence: a pre-adverse action notice with a copy of the report and the Summary of Your Rights Under the FCRA, a reasonable waiting period so the applicant can respond, and then the final adverse action notice.
How do Cascades' flows map to that?
| Flow | Sequence | What the node sends |
|---|---|---|
tenant_screening, credit_lending |
one notice (notice_stage: final) |
The operator's notice template rendered to PDF with the selected reasons, emailed to the applicant; execution status is updated and adverse_action.triggered + adverse_action.completed fire together |
employment |
pre_adverse → wait → post_adverse |
The pre-adverse notice with the upstream report PDFs and the Summary of Rights attached; the execution waits (floored to 5 days); then the final notice; adverse_action.triggered at the first send, adverse_action.completed at the second |
The node's default send_strategy is draft_first: a decline parks an editable draft for a person to review and send. Unattended sending (auto_send) is a per-node opt-in. In human-review mode the reviewer's Deny dialog shows the pre-selected reasons and can edit them or skip the notice; a skip is recorded as notice_intentionally_skipped in the audit trail. Details: Adverse action.
Which reasons can a notice carry?
Reasons are chosen from a fixed vocabulary, mapped from the decision conditions that failed (the mapping is editable by compliance without a deploy). Each has an English and a Spanish label.
| Key | Label |
|---|---|
credit_score_low |
Credit score does not meet minimum requirements |
insufficient_credit_history |
Insufficient credit history |
delinquent_accounts |
Delinquent past or present credit obligations |
too_many_inquiries |
Too many inquiries in the last 12 months |
public_record |
Public record (bankruptcy, judgment, lien) |
collections |
Collection accounts on credit report |
high_debt_ratio |
Debt-to-income ratio is too high |
insufficient_income |
Insufficient income for the obligation |
employment_not_verified |
Unable to verify employment |
identity_not_verified |
Unable to verify identity |
residence_not_verified |
Unable to verify residence history |
criminal_record |
Criminal record found |
eviction_record |
Eviction record found |
sex_offender_registry |
Sex offender registry match |
terrorist_watchlist |
Terrorist watchlist match |
fraud_alert |
Fraud alert or security freeze on credit file |
incomplete_application |
Incomplete application |
excessive_obligations |
Excessive obligations in relation to income |
lack_of_references |
Lack of acceptable references |
length_of_employment |
Length of employment insufficient |
prior_lease_violations |
Prior lease violations or negative rental history |
insufficient_assets |
Insufficient assets or reserves |
other |
Other (see additional notes) |
Account types on the notice: credit, mortgage, insurance, employment, tenant screening / rental, other. Action types: application denied, credit revoked or terms changed unfavourably, adverse employment action taken, other action taken.
What is your responsibility?
- Template content. Cascades renders your template. The agency identification, the rights statements, score disclosure and any state-specific language must be in it. Templates are versioned; every sent notice records the template version used.
- Recipient and delivery. The node emails the applicant at the address in the payload. Delivery failures surface as
adverse_action.failed; the execution and audit dashboard show the state. If your policy requires postal delivery, or the applicant has no email, you must handle that outside Cascades. - Timing. The employment waiting period is enforced at a minimum of five days; longer periods are configurable on the node. For other flows, the notice is sent when the decision is recorded.
- Individualised assessment and local rules. Criminal-record and eviction decisions are subject to fair-housing and state and municipal rules (look-back limits, individualised assessment, ban-the-box). The cascade evaluates the rules you write; whether those rules are lawful where you operate is your call.
- Records. Keep the audit trail (
GET /executions/{id}/review_events), the notice artifacts (GET /executions/{id}/notice_artifacts) and your own application record together for the retention period your counsel advises.
Related
- Adverse action — the mechanics and webhook events
- FCRA permissible purpose
- Webhook events