We have some maturing HELOCs and the lenders want to "streamline" the process and pull credit before we send the 60-day maturity notice (our credit agreement contains language that allows us to pull credit). The process would be to notify customers by phone and on their monthly statements that their lines are about to mature. For the qualified candidates, we'd ask them to come in and apply and for those with credit scores below our threshold, we would tell them that the loan is about to mature and we will not be renewing the line. The lenders think this will benefit struggling borrowers by avoiding late fees and saving time. They asked compliance if they should send out written adverse actions notices and/or FACT Act (decision based on credit rating) notices for the maturing loans that won't be re-newed. I'm glad they asked me about the notices, but I'm more concerned about potential fair lending (discouragement), since we've not taken an application for credit and haven't given additional consideration to LTV of DTI etc. Any thoughts?

This would be considered pull credit reports for marketing purposes unless the current credit agreement outlines the renewal guidelines and parameters. IMHO - you do not have a permissible purpose and the pulling of the credit report has nothing to do with the review or collection of the current loan.