Closing LOCs b/c Dormant/Inactive for 24 Months
Answer by Randy Carey, BOL Guru Guru Bios
Question: We are wanting to close LOCs that have remained dormant or inactive for longer than 24 months. Does this require an adverse action notice? If so, do we need to include the new credit report key factors?
Answer: Regulation B
Sec. 202.2 Definitions
(c) Adverse action—
(2) The term does not include:
(ii) Any action or forbearance relating to an account taken in connection with inactivity, default, or delinquency as to that account;
However, if your loan contract does not indicate that this will happen, it would probably be wise to give them prior notice that you are cancelling thier line.
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