Click to return to BOL home page
Banker Store Read A Reg BOL Insiders Career Connect Learning Connect Bankers Information Network



July 15, 2015
All About Escrows
David Dickinson

July 16, 2015
Business or Consumer Purpose, That Is the Question!
Kathleen Blanchard

July 21, 2015
Efficient SAR Narratives: Beyond the 5 W's
Victor Cardona

July 22, 2015
How to Complete the Loan Estimate
Jerod Moyer

July 28, 2015
Opening Nonprofit, Memorial, Donation, Association Accounts and more
Deborah Crawford

July 29, 2015
How to Complete the Closing Disclosure
Jerod Moyer



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

Registered: 08/14/01
Posts: 6011
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?
_________________________
The more you sweat in training, the less you bleed in battle.......

Top
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: 42222
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.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Top

Moderator:  Andy Z