Reason required by law
Microloans are made by nonprofit intermediaries rather than banks, and they are the part of the federal toolkit built for exactly the file a bank declines without explanation — thinner history, smaller ask, less collateral.
Still credit, still Regulation B. And intermediaries are typically far more willing to tell you what was missing, because telling you is closer to their mission than protecting a credit box.
This is a credit application. A denial is adverse action, and under Regulation B you can require a specific written reason.
What the law actually says
The Equal Credit Opportunity Act and its Regulation B govern business credit, not just consumer credit. 12 CFR 1002.9 sets what a lender owes you when it says no, and it turns on your own revenue:
| Your gross revenue last fiscal year | What the lender owes you |
|---|---|
| $1 million or less | Notice of the decision within 30 days of a completed application. You may request the reasons within 60 days, and the lender must answer within 30 days of your written request. |
| More than $1 million | Notice within a reasonable time, orally or in writing. Reasons only if you make a written request within 60 days. |
The part almost nobody is told. Under 1002.9(a)(2) the statement of reasons must be specific. The regulation says outright that pointing to "internal standards or policies," or telling you that you "failed to achieve a qualifying score," is insufficient.
So the brush-off is not the lender exercising judgment. On a business credit application, after a written request, the brush-off is the thing the rule already prohibits. 87% of white owners get a reason. 51% of Latino owners do. The right is identical. The delivery is not.
This is what the regulation says, cited so you can read it yourself rather than take our word for it. It is not legal advice, and a lawyer or your SBDC can tell you how it applies to your file.
How to ask, in one paragraph
Put it in writing within 60 days, keep a copy, and use words that track the regulation:
"I am requesting a written statement of the specific principal reasons for the adverse action taken on my business credit application dated ____, as provided under the Equal Credit Opportunity Act and Regulation B, 12 CFR 1002.9."
Email is writing. Send it to the loan officer and to the bank's compliance address. If what comes back names internal policy or a score and nothing else, that is not a compliant answer — say so, in writing, and copy your SBDC.
Where you are matters
Ten states have a commercial financing disclosure law in effect and forty-one do not. Regulation B applies in all of them.