Bank determines it wants to terminate a "special" credit card program.

Do we use the 45-Day Change-in-Terms Notice including following the repayment methods allowed under 12 CFR 1026.55 (c) (2)?

Are you changing the customers to a new credit card program? If so, you can provide a change in terms. If not, you need to send these customers an AAN - you are cancelling (denying) the program.

No - the Bank would be cancelling (denying) the program. There are consumer and commercial credit cards in this "special" credit card program.

Are there specific regulatory requirements for handling payment of the outstanding balance on the cards impacted?

Payment terms should be in your agreement.

I do not believe what they are doing meets the definition of Adverse Action. From 1002.2:

(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;


Canceling the program would affect all or substantially all of the borrowers within that class of accounts.