We are planning to offer an unsecured revolving 5 year LOC. We plan to do a semi -annual review and remove the borrower's revolving privileges if the credit score does not meet our requirements. My question is - does the borrower have the right to appeal this? Would this fall under FCRA? If so, can someone point me to a site reference please.

Thank you,

You would be taking adverse action against the consumer based on information from a consumer report. FCRA would apply. You would also have to send an AAN under Reg. B.

if the credit score does not meet our requirements

Keep in mind you have to give them specific reasons for the adverse action which means you have to give the reasons they did not meet your score requirement.

ILG, as with any denied application, the borrower could appeal. If they do, I would use some of the time to look over any similarly situated applicants and decisions to ensure that they are treated fairly, then, like Dan said, deny them.