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#2153572 - 11/14/17 10:54 PM Adverse Action Notice
ns Offline
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Joined: Aug 2016
Posts: 120
We have a credit card partner that is proposing to make an addendum in their credit policy that would not allow for Credit Limit Increases going forward. I'd like clarification if an adverse action notice would be required for applicants that request a CLI after the change to the policy is made? My interpretation is because it is going to affect all of a class of the creditor's accounts an AAN would not be required by Reg B. Agree?

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#2153575 - 11/14/17 11:03 PM Re: Adverse Action Notice ns
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,959
Galveston, TX
Why would you not grant them a new card with a higher credit limit? Seems a little draconian to me if they later qualify for a higher limit. Why would you treat an existing customer different than one that walked in off the street.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2153606 - 11/15/17 02:41 PM Re: Adverse Action Notice ns
ns Offline
100 Club
Joined: Aug 2016
Posts: 120
I apologize as I did not provide all the details. The portfolio is winding down and they are going to update the credit policy to state CLI's will not be allowed going forward but we weren't sure if it qualified as an adverse action that would require the notice. My interpretation is that since it is affecting all classes it would not be an adverse action.

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#2153609 - 11/15/17 02:47 PM Re: Adverse Action Notice ns
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,959
Galveston, TX
If you are not going to offer credit cards in the future, then I think a request for an increase in the credit limit on a product that you no longer offer would fall under:

(c) Adverse action.

(2) The term does not include:

(v) A refusal to extend credit because the creditor does not offer the type of credit or credit plan requested.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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