---
title: Adverse action notices
description: What an FCRA adverse-action notice must contain, how Cascades' single-notice and employment flows meet it, the reason vocabulary, and what stays yours.
canonical_url: "https://cascades.crscreditapi.com/docs/compliance/adverse-action-notices"
doc_version: "1.0.0"
last_updated: "2026-09-23T19:55:02Z"
source: docs/compliance/adverse-action-notices.md
---

# Adverse action notices

> [!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](/docs/concepts/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](/docs/concepts/adverse-action) — the mechanics and webhook events
- [FCRA permissible purpose](/docs/compliance/fcra-permissible-purpose)
- [Webhook events](/docs/api/webhooks)

## Sitemap

See the full [sitemap](https://cascades.crscreditapi.com/sitemap.md) for all pages.