If a customer request that we release part of their collateral and we run a credit report to see if we would do it would we have to give an notice of adverse action if we refuse?

Yes, Reg. B applies to the request for a credit accomodation by the customer. If you don't "originate" (by releasing the collateral in your example), then you have taken adverse action and must provide the required notice.

Al

No. Not unless the borrower submitted an application for a refinance of the loan. Otherwise, you would not be denying a request for credit.

Oh gee....well never mind.....looks like I disagree with the "big wig." Go with what he says.