How do I create adverse action reasons if I am using V-Max to make decisions that require the disclosure of such reasons?
As is always the case with government regulations, the language used in defining Regulation B is not terribly specific. It is likely that you would use the reasons from the factors or models that you are using today, so long as those models were components of V-Max. It is always advisable to consult with your legal counsel before making such decisions.
