THIS CONTENT REFLECTS THE PHILOSOPHY OF BOYLEDOWN LENDING INC., A CONSUMER FINANCE COMPANY LICENSED BY THE VIRGINIA STATE CORPORATION COMMISSION (LICENSE number CFI-256). IT IS INTENDED AS INFORMATIONAL CONTENT AND PROMOTES OUR LENDING MODEL. AS SUCH, IT IS CONSIDERED AN ADVERTISEMENT.
AI Disclosure:
This article was developed with the assistance of artificial intelligence (AI) using OpenAI’s ChatGPT. While the ideas and editorial direction reflect the author’s perspective, portions of the research, structuring, and drafting were supported by AI-generated insights. All content was reviewed and finalized by the author.
In today’s world of algorithmic lending, many credit decisions are made by automated systems. These systems evaluate your application using proprietary models—commonly called “black boxes.” If you’re denied credit, you’ll receive an adverse action notice, often listing a general reason like:
“Income insufficient for amount of credit requested.”
This kind of explanation is legal.
It’s pulled from a standardized list in Appendix C of Regulation B, and the lender is not required to show you their algorithm or reveal their secret sauce as long as the statement of reasons for adverse action are specific and state the principal reason(s) for the adverse action.
But what if that principle reason(s) for the adverse action simply don’t make sense?
🎯 You Have More Power Than You Think — But Timing Is Everything
When you’re applying for a loan and still in the running, you have market leverage: the lender wants your business, so asking about things like origination fees or pricing logic might get you more specific responses.
But when you’re denied, that leverage disappears. You can’t walk away from a deal that was already rejected.
So what’s left?
Cross-referencing your financial profile with the principal reasons for loan denial in the adverse action notice — and how well it aligns (or doesn’t) with the reason(s) you were given.
🔍 Step One: Review the Adverse Action Reason
Don’t dismiss that single-line explanation. Look closely. Was the reason:
- No credit profile
- Insufficient income
- Excessive obligations in relation to income
- Delinquent past or present credit obligations with others
These are acceptable adverse reasons. But are those specific descriptions THE ACTUAL PRINCIPAL REASONS for loan denial as applied to YOUR adverse action?
📁 Step Two: Pull Your Financial Profile
To raise a challenge to that you have to look at those specific reasons and be able to make an evidence-based argument that can refute them as being valid principal reasons for your case.
Sometimes this is easy. For example:
If an adverse action states that you have insufficient income for a $3000 personal loan, and you show a million dollars in annual income and zero debt, something seems really off. The lender owes you an explanation. Otherwise it is easy to see how this could be an unfair practice and a Reg B compliance failure.
Those are unusual scenarios though. Normally arguing that the specific adverse action reason(s) are not valid principal reasons for loan denial isn’t such direct logic. Rather than clearly refute, you’ll have to build enough of a case to show a credible discrepancy between adverse action reasons stated and the realities of your financial profile. That will require opening your own books and finding counter-evidence to the principal reason(s) claimed.
Depending on the specific reason(s) provided that could mean finding evidence by,
- Downloading credit reports
- Looking at your income, debts, payment history and employment history.
- Comparing that financial information with the reason given in the adverse action notice.
🛠️ Step Three: Build a Good-Faith Challenge
You’re not saying:
“You’re hiding your algorithm, and I demand to see it.”
Instead, you’re saying:
“Based on my actual income and credit profile, the reason you gave doesn’t seem to apply. Can you clarify what specific factors led to this conclusion?”
This is a respectful challenge that does not demand the lender sacrifice trade secrets — it simply demands a decision that makes logical sense given your financial facts. Again, under this argument, you are not saying the reasons are invalid for anyone, you are saying they are invalid AS APPLIED TO YOU.
🔓 Step Four: The Moment the Black Box Must Crack (A Little)
At this point, the lender has a choice:
- Engage in good faith and offer a more specific or refined explanation
- Or double down on vagueness, refusing to clarify despite a reasonable challenge
If it’s the latter, now you’re in business review or regulatory complaint territory — and rightly so.
You’re not writing a negative review or filing a regulatory complaint because the lender is guarding a trade secret– which is their right.
You’re filing because:
- The adverse action principal reason(s) given do not appear factually accurate
- The lender refused to clarify, even when presented with reasonable counterevidence
- That raises a fair question about whether the decision process is reliable, transparent, or fair
This is what Regulation B is supposed to prevent: adverse actions that are opaque and unchallengeable, even when the applicant has done everything right. Unfair or deceptive or abusive practices laws exist for similar reasons.
💬 Step Five: Leave a Respectful but Honest Public Review or Complaint
You now also have a legitimate basis to leave a review to the business or a complaint to a regulator stating something like:
“I was denied credit and received a general explanation that didn’t match my actual financial profile. When I asked for clarification, I was met with vague replies. I understand that companies protect their proprietary models, but when the reasons don’t match the facts, borrowers deserve more transparency. Disappointed in how this was handled.”
You’re not trashing the lender. You’re documenting a [potential] transparency failure — and this may help future borrowers, encourage better practices, and nudge the market toward more openness. According to the CFPB, most lenders respond within 15 days to a complaint (Each week the CFPB sends more than 50,000 complaints about financial products and services to companies for response. If another agency would be better able to assist, we’ll [the CFPB] send it to them and let you know).
Understand also that at any of these points the lender can respond clearly showing that THERE WAS NO TRANSPARENCY failure. Providing enough evidence to warrant a deeper dive by the lender does NOT MEAN the lender was ever in the wrong.
✅ Summary: What Makes Your Complaint or Review Legitimate
| ✅ You’re Not Doing This… | ✅ You Are Doing This… |
|---|---|
| Demanding proprietary algorithm access | Asking for clarification on a reason that doesn’t add up |
| Claiming wrongdoing without cause | Challenging with specific financial evidence |
| Filing a frivolous complaint | Raising a valid regulatory issue based on inconsistency |
| Leaving a rage-fueled review | Posting a thoughtful critique highlighting the disconnect |
💡 Final Thought
Black-box decisions don’t mean borrowers are powerless. If you’re armed with your own financial truth, you can question vague denials and hold lenders to a higher standard — not by attacking their trade secrets, but by insisting that the reasons they give must at least make sense.
That’s not just fair — it’s the basis of a well-functioning credit system.
Email: doboyled@gmail.com
Phone: (631) 379‑0306
Mailing Address:
Boyledown Lending Inc.
285 Crockett Hill Lane
Cross Junction, VA 22625
Boyledown Lending Inc. 
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