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#1857833 - 10/02/13 08:00 PM AAN on Existing Account - HELOC - Credit Cards
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Joined: Nov 2008
Posts: 1,064
In the mountains
In the following scenarios would an ECOA AAN be required?:

We do not receive proof of hazard or flood insurance on the property securing the HELOC so the line is frozen.

Credit card accounts are closed due to past due status.

Or is a letter just basically stating that the account was frozen or closed with the reason all that is needed?
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Fair Lending
#1857916 - 10/02/13 11:46 PM Re: AAN on Existing Account - HELOC - Credit Cards Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
IF the loan is currently in default and you are taking actions based on that fact, that is not adverse action.
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#1857942 - 10/03/13 12:30 PM Re: AAN on Existing Account - HELOC - Credit Cards Likes to Comply
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Diamond Poster
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Posts: 1,064
In the mountains
Thanks smile
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#1858113 - 10/03/13 04:23 PM Re: AAN on Existing Account - HELOC - Credit Cards Likes to Comply
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,016
Bloomington, IN
Or is a letter just basically stating that the account was frozen or closed with the reason all that is needed?

If you suspend or terminate a HELOC there are specific monitroing/notification requirements, outside of ECOA, found in 1026.40 and 1026.9.
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