Explain the reasons for a credit denial in an adverse action notice

Help me write the statement of reasons for an adverse action notice on a credit application. Product: [consumer or business credit - e.g. "credit card", "auto loan", "small business line"] Action taken: [declined / approved on different terms (counteroffer) / account closed or limit reduced] Decision factors from our underwriting or model: [LIST the actual factors in order of importance - e.g. "debt-to-income 52%, policy max 43%"] Was a credit report or score used? [yes/no; bureau name; score and key factors if provided] Jurisdiction: [e.g. "US" plus state] Do this: 1. Turn the factors into up to four principal reasons written in specific, plain language (for US consumer credit, the reasons must reflect the actual factors - avoid vague phrases like "internal standards" or "insufficient score"). 2. Check each reason against prohibited bases and flag any factor that could be or act as a proxy for a protected characteristic (e.g. age, marital status, receipt of public assistance, ZIP code). 3. List the other elements the notice typically needs for this situation - e.g. the creditor's details, the ECOA anti-discrimination notice and regulator, and, if a consumer report was used, the credit reporting agency details, the score disclosure, and the applicant's right to a free report and to dispute - as a checklist marked [CONFIRM with our template]. 4. Flag if the counteroffer scenario changes what must be sent. Do not invent reasons that are not in my list. This is general information, not legal advice; have compliance or counsel confirm the final notice against current regulations and our approved templates.