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#2168401 - 03/15/18 04:39 PM ECOA AAN - Credit Overdraft Decline
Compliance NABW Offline
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Is an AAN required for a Line of Credit that is tied to a deposit account to cover Overdrafts if for whatever reason the Bank refused to cover an Overdraft with an advance on the line?

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#2168403 - 03/15/18 04:40 PM Re: ECOA AAN - Credit Overdraft Decline Compliance NABW
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Huh? If you haven't terminated the line, how can you refuse to advance?
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#2168424 - 03/15/18 05:43 PM Re: ECOA AAN - Credit Overdraft Decline Compliance NABW
Compliance NABW Offline
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Joined: Oct 2015
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One example I can think of is let's say there is a limit on the Overdraft line, such as $1,000 and the transaction would push it above that. Not sure of other situations I can come up with, maybe if the Bank thought the Overdraft was from a fraudulent transaction and so declined to process and advance the funds. Maybe this isn't a valid question. But, if for ANY reason, an advance was not allowed, is this Adverse Action under ECOA?

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#2168450 - 03/15/18 07:16 PM Re: ECOA AAN - Credit Overdraft Decline Compliance NABW
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
If you do anything outside of what your current legal obligation allows you to do - yes.
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