Skip to content
GeoDataVision
Thread Options
#186457 - 05/04/04 02:42 PM Reason For Adverse Action
Beagles22 Offline
Power Poster
Joined: Jan 2004
Posts: 3,626
State of confusion
We have a customer with a loan and deposit accounts with our institution but has moved out of the state (8 months ago). They have applied for a credit card for $17,000 which is a)more than we lend on an unsecured status b)they are out of our lending area. Can you mark on the denial notice other and put out of lending area? Can we put no collateral offered even though we don't require collateral on credit cards but would on that dollar amount? Any advice would be greatly appreciated.
_________________________
Going to church doesn't make you a christian any more that standing in your garage makes you a car.

Return to Top
Lending Compliance
#186458 - 05/04/04 03:46 PM Re: Reason For Adverse Action
Tom Easterday Offline
100 Club
Joined: Oct 2000
Posts: 140
Orange County, CA
I'd use "terms & conditions not offered" as the primary reason for the decline, but make sure that you don't have other credit card accounts at or near that dollar amount. Being out of your service area can be a legitimate decline reason if your institution's lending policy has geographical boundaries and in reality you don't make loans to others who live out of the deliniated area.
_________________________
Tom Easterday, CRCM Opinions stated are my own and not necessarily those of my employer!

Return to Top
#186459 - 05/06/04 01:55 PM Re: Reason For Adverse Action
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,502
On the Net
Tom provides good advice. You don't want to deny an unsecured request for insufficient collateral, none was offered. You don't want to tell them they need to provide collateral, if you don't accept it. What if he comes up with collateral? You still don't want the deal. Each of these could be deemed inappropriate in a Reg. B audit.

Terms and conditions and out of area are sufficient. Be sure the "area" issue is a policy you follow. This can be supported by CRA easily. Hopefully these are supported by your policy and practices.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#186460 - 05/06/04 03:26 PM Re: Reason For Adverse Action
Beagles22 Offline
Power Poster
Joined: Jan 2004
Posts: 3,626
State of confusion
Thanks! I did review our lending policy and it had our lending area by county and surrounding areas laid out. We do not lend out of the state. The terms and conditions I didn't use as we do have a couple of credit cards with limits higher than the one requested by this customer. Thanks again for the help!
_________________________
Going to church doesn't make you a christian any more that standing in your garage makes you a car.

Return to Top

Moderator:  Andy_Z