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April 22
A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina



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

Registered: 08/14/01
Posts: 5588
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: 40004
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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