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#1268657 - 10/17/09 06:35 PM Be careful about inquiring on your rev credit acct
Anonymous
Unregistered

I just experienced a total shut down of all my credit from BOA. I inquired about a transaction on my credit card and the next day i noticed my credit limit on my 2 cards was cut thousands of dollars. No notice or warning.I'm glad i wasn't out trying to purchase something, that would have been embarrasing. I have been a longstanding customer, have excellent credit, never late. Those things don't matter anymore. We hear about this happening out there but when it happens to you it really hits home. I feel like a irresponsible thug, not a valued customer. Just had to vent.

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#1268660 - 10/18/09 12:43 AM Re: Be careful about inquiring on your rev credit acct Anonymous
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Unfortunately lots of others are doing it too.
Not just BOA.
It is the times.

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#1268661 - 10/18/09 12:13 PM Re: Be careful about inquiring on your rev credit acct MagicCity
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
They owe you an adverse action notice under Regulation B.

Adverse actionó(1) The term means:

(ii) A termination of an account or an unfavorable change in the terms of an account that does not affect all or substantially all of a class of the creditor's accounts;
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1268663 - 10/18/09 01:11 PM Re: Be careful about inquiring on your rev credit acct rlcarey
Anonymous
Unregistered

Thanks Randy,

I thought so. Never received anything.

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#1268664 - 10/18/09 01:12 PM Re: Be careful about inquiring on your rev credit acct MagicCity
Anonymous
Unregistered

I know your right. It's really tough times.

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#1276741 - 10/29/09 01:53 PM Re: Be careful about inquiring on your rev credit acct Anonymous
Anonymous
Unregistered

You should re-read the new 226.5 effective Aug. 20th. Credit Card financial do not need to give notice of account closure and BOA did under the rules include an entire class of creditor's, most of their good customers who had higher credit limits with low to no balances & those with higher balances and only making min. installment payment. Albeit BOA motives were both to reduce perceived credit risk and as a knee jerk reaction to the CCARDA laws. A new wave of fee based credit cards will begin to appear soon costing consumers even more for open-end credit tied to plastic.

There are no winners here, thank you congress!

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#1278766 - 11/02/09 09:59 PM Re: Be careful about inquiring on your rev credit acct Anonymous
NotALawyer Offline
Gold Star
NotALawyer
Joined: Nov 2001
Posts: 455
Originally Posted By: Anonymous
You should re-read the new 226.5 effective Aug. 20th. Credit Card financial do not need to give notice of account closure and BOA did under the rules include an entire class of creditor's, most of their good customers who had higher credit limits with low to no balances & those with higher balances and only making min. installment payment. Albeit BOA motives were both to reduce perceived credit risk and as a knee jerk reaction to the CCARDA laws. A new wave of fee based credit cards will begin to appear soon costing consumers even more for open-end credit tied to plastic.

There are no winners here, thank you congress!



I can't find in 226.5 where it says this. Can you point to the part that calls this out? Also, this doesn't appear to be consistent with the definition of adverse action in 202.2(c)(1)(ii), so why again is a notice not required? The exclusion applies to actions that impact all or substantially all of a class of the creditor's accounts. Your example is that "most" accounts that meet certain criteria around paydown rates (one example). Not eveyone has a high line or a high line with low paydown. I read this as different than "all or substantially all", particularly when compared to current practices of cancelling all accounts that have a bankruptcy filing notice - everyone with a notice is cancelled, but each person also receives an adverse action notice with reasons.

Not trying to argue, just trying to more clearly understanding the reasoning.

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#1278859 - 11/03/09 07:01 AM Re: Be careful about inquiring on your rev credit acct NotALawyer
Anonymous
Unregistered

An Adverse Action Notice is in connection to a creditors response to a request from a borrower for credit. For example, a borrower request a higher card credit limit and the creditor denies the request, an Adverse Action Notice is required. If it was required in the for adjustments made to cardholder accounts, don't you think the Credit Card Companies would have done so rather than risk a considerable violation and substantial costs & CMP?
When a Creditor, as under the new CCARDA unilaterally decides to review all its borrower credit card accounts for those that do not represent a reasonable assumption of ability to repay the credit advanced on the card account, i.e. deterioration of credit worthiness, the creditor can predefine a class of cardholders that do not present a good risk profile and therefore are not likely to repay the debt in a timely and prudent manner, it is mining data for specific characteristics such as those outlined previously.

The new CCARDA rules do not conflict with Reg. B, the credit cards are already on the creditors books and under CCARDA, the creditor is not required to give Notice to the card holders of an identified "class" of cardholders from within its universe of cardholder data that they individually pose a poor risk to the creditor. However I believe they should send their borrowers' a letter at some point explaining their action with regard to action it's taken on the borrower's credit status as part of the class or group. Again as noted in the previous examples the are several different parameters' used in underwriting each "class" or group. The credit card grantor is required to review each class at intervals (I believe approx. every 6 months), to determine if the individual card holders in a class have moved out of or into a predefined class based on economic conditions and the previously defined parameters'.

The Reg. Z, T-I-L disclosure amendments under CCARDA, are complex. Sometime after the full phase in of the various parts of the disclosure requirements under CCARDA, there should be more stabilization of how credit card companies treat their customers. Right now they are and allowed to cut risky credit card account out (close acct.) and reduce limits without notice. They can't (after Aug. 20th) unilaterally raise interest rates without 45 days notice and providing an interest rate increase Opt-Out provision. If exercised by the cardholder, this usually means the card acct. will be closed with the interest rate fixed at the pre-rise rate for the remaining balance, unless the cardholder defaults on minimum payments.
I disagree with the premise that a Notice of Adverse Action applies to any of the CCARDA notification rules as they are now written under the current Reg. Z Part 226 Interim Final Rules.

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#1280591 - 11/04/09 06:25 PM Re: Be careful about inquiring on your rev credit acct Anonymous
Anonymous
Unregistered

They have 30 days to notify you of the adverse action. There is nothing in regulations that states they have to provide you notice prior to taking the action. I know because it happened to me recently.

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#1291226 - 11/22/09 11:09 PM Re: Be careful about inquiring on your rev credit acct Anonymous
Anonymous
Unregistered

Original Anon here: Hold on to your hats, your not going to believe this, i am still in shock!

I eventually decided to vent my frustration with the attorney general's office via email. I figured that was the official end of it for me.

I receive a phone call about 3 weeks later from the office of Ken Lewis (BOA).

Bottom line, they told me that i should have been told in my conversation with the employee that i was doing the inquiry with that my credit was going to be cut. They said they were reinstating my credit limit to XXXXX almost to what i had before,and they did. So much for i'm sorry Mr. or Mrs. XXXX there is nothing we can do (from the credit analyst). It's amazing what a little pressure can sometimes accomplish.

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#1291232 - 11/23/09 07:40 AM Re: Be careful about inquiring on your rev credit acct Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
I guess under the current circumstances Ken Lewis has little else to do smile
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1291274 - 11/23/09 01:57 PM Re: Be careful about inquiring on your rev credit acct rlcarey
Anonymous
Unregistered

lol

true!

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