Good morning,

Our compliance office is out this week and I've been sent a few questions about credit cards that I need some assistance with. Any regulatory citations would be much appreciated while I continue to dig for the answers myself.

1) If a credit card is being canceled due to lack of use, are we required to notify the customer? Our plan is to review their credit to see if they are using credit, and if so, to send a letter explaining what is happening, reinterating the benefits of the card and offering opportunity to notify us if they would like the account to remain open. Thoughts?

2) If the account is being canceled due to delinquency on the card or deterioration of overall credit since the card was opened, we were planning to put together an adverse action letter, but are unsure what needs to be included in this letter. Help?

3) There are some business cards that we are not reissuing because the business no longer exists. Are we required to send a notice?

4) We are pulling "soft" credit bureaus on each of the consumer accounts for the review. Do we need to send a credit score disclosure?

Many thanks in advance.

1, 2, & 3. See the definition of Adverse Action in Reg. B 1002.2(c) and its Commentary.

4. If information in the consumer report is used in whole or in part in any adverse action the required disclosures would be required.