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December 3, 2014
Overdrafts: Latest Regulatory Feedback, Guidance & Best Practices Webinar
David Dickinson and Jerod Moyer

December 4, 2014
Freebies, Bonuses and Contests
John Burnett and Andy Zavoina

December 9, 2014
Bankruptcy: Creditor Do's and Don'ts
Sam Ott

December 10, 2014
Branch Audits: What Is Going On Out There?
Patricia Cashman

December 17, 2014
Integrated Disclosures - An Implementation Strategy
Mary Beth Guard and Jack Holzknecht

December 18, 2014
Loan Review Best Practices for a Community Bank
Bob Fritzlan

December 19, 2014
PREPAID PRODUCTS - Understanding the CFPB Proposal
John Burnett



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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: 5797
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: 41062
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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