Can we cancel a credit card without the cardholder's consent if they haven't activated their credit card in a certain time frame? We have cardholders that haven't activated their cards in twelve months.

Yes. See 1002.2(c)(2)(ii). It would not fall within the definition of adverse action.

If you don't run your credit card program in-house, make sure you check your agreement with your processor. We stumbled across a comment that they won't allow us to do a mass de-activation of dormant/inactive cards (presumably because their loss in fee income), so when we wanted to remove a bunch, we found we couldn't.

You want to make sure that your actual credit card loan contract allows it also.

I came across this thread and have a related question. If the reason to cancel is due to exceeding the credit limit, it appears that would be considered adverse action. It appears that canceling for delinquency or inactivity would not be adverse action.

(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; or

Is the reason "exceeds the credit limit" specific enough for the adverse action notice? The card agreement does provide that the account could be closed for any reason.

Thank you!