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September 8
Checkup for your RDC Program;
Susan Orr

September 10
Critical Issues on Certificates of Deposit;
Deborah Crawford

September 16
S.A.F.E. Act - Auditing for Compliance;
Patricia Cashman

September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott

September 24
Using CPTED to Make Our Banks Safer;
Dana Turner and Carol Dodgen



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#653838 - 12/18/06 04:03 PM Termination of Line of Credit Due to Inactivity
swiggles Offline
Power Poster

Registered: 08/14/01
Posts: 5759
One of our loan products is an open-end personal line of credit (no plastic). Management wants to terminate any of these that have not had activity in the past year. I thought that an adverse action form would be in order, but when I looked in Reg B, I discovered that 202.2(c)(2)(ii) states that any action relating to an account in connection with inactivity is not considered adverse. Management intends to send a letter to each inactive account holder. Is that all that is necessary? Are there any timing requirements connected to the closure?
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The more you sweat in training, the less you bleed in battle.......

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Lending Compliance
#653868 - 12/18/06 04:26 PM Re: Termination of Line of Credit Due to Inactivity [Re: swiggles]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 40643
Loc: Bloomington, IN
Closing an account for inactivity does not meet the definition of adverse action and there is no notice requirment under Reg. B. However, your contract may have such a requirement.
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The opinions expressed are mine and they are not to be taken as legal advice.

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