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#199227 - 06/10/04 08:18 PM Reg B - Adverse Action
DMG Offline
Junior Member
Joined: Jun 2004
Posts: 37
Midwest
Looking for opinions - does anyone think that "We do not offer credit in the terms and condition you requested" is sufficient enough as a denial reason or should there be more, such as what part of the request was unacceptable?

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Lending Compliance
#199228 - 06/10/04 08:24 PM Re: Reg B - Adverse Action
deppfan Offline
Power Poster
Joined: Dec 2000
Posts: 5,184
All over the map.
We have used very similar language and never had it questioned by examiners. Just make sure you never offer the credit terms they are asking for to anyone else.
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#199229 - 06/10/04 08:38 PM Re: Reg B - Adverse Action
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I don't disagree, but wanted to clarify. Not offering a type of loan is not adverse action [See ยง202.2(c)(2)(v) A refusal to extend credit because the creditor does not offer the type of credit or credit plan requested.]
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David Dickinson
http://www.bankerscompliance.com

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