up to four key factors that adversely affected the consumer's credit score (or up to five factors if the number of inquiries made with respect to that consumer report is a key factor). Community banks must effectively balance their customers' need for credit with the risk inherent in lending. A creditor may be faced with numerous reasons to take adverse action. The challenge is to pare down those reasons and give the customers sufficient information but not so much that it is overwhelming to a customer. When an action to deny credit or to take adverse action on an existing account is necessary, the best practice is to conduct a robust review of the negative factors, prune them to no more than four and ensure the file is fully documented to show the path to the disclosed results. Mary Thorson Wright, a former Federal Reserve examiner, is a financial writer in Virginia. HAVE YOU OPENED THE COMPLIANCE VAULT YET? It contains answers to more than 1,500 regulatory questions, plus access to eLearning courses and documents. Sign up today: icba.org/compliancevault Compliance calendar A look at upcoming regulatory changes April 1, 2018 Effective date for final rule implementing requirements for prepaid accounts (Regulation E)* and for Mortgage Servicing Amendment (Regulations X and Z, and FDCPA) May 11, 2018 Effective date for customer due-diligence requirements (beneficial owner rule) Visit icba.org/compliance/ regulatory-calendar for more. *CFPB may extend this deadline ______________http://www.icba.org/compliancevault http://www.icba.org/compliance/