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?

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.