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#186457 - 05/04/04 02:42 PM Reason For Adverse Action
Beagles22 Offline
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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.
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Lending Compliance
#186458 - 05/04/04 03:46 PM Re: Reason For Adverse Action
Tom Easterday Offline
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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.
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#186459 - 05/06/04 01:55 PM Re: Reason For Adverse Action
Andy_Z Offline
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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.
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#186460 - 05/06/04 03:26 PM Re: Reason For Adverse Action
Beagles22 Offline
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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!
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