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#2178904 - 05/21/18 03:21 PM Unsecured Open End Credit - Suspended - Appeal
I luv Giraffes Offline
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Joined: Sep 2008
Posts: 73
Where do I find in FCRA the borrower's appeal process requirements after a draw suspension of their unsecured open end credit?
Thank you.

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#2178926 - 05/21/18 04:24 PM Re: Unsecured Open End Credit - Suspended - Appeal I luv Giraffes
rlcarey Offline
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rlcarey
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Galveston, TX
Why would that be in the FCRA?
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#2178930 - 05/21/18 04:32 PM Re: Unsecured Open End Credit - Suspended - Appeal I luv Giraffes
I luv Giraffes Offline
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Not sure. I looked in Reg Z and did not find support for this. Did I overlook something in Reg Z?

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#2178941 - 05/21/18 04:55 PM Re: Unsecured Open End Credit - Suspended - Appeal I luv Giraffes
rlcarey Offline
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rlcarey
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Galveston, TX
Sounds like you need to be reviewing your loan contract. What does it say about suspension. You also need to review Regulation B regarding adverse action. Are you saying you suspended it because you pulled a new credit report??
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#2178955 - 05/21/18 05:37 PM Re: Unsecured Open End Credit - Suspended - Appeal I luv Giraffes
I luv Giraffes Offline
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Posts: 73
Is there any regulatory guidance for how long the borrower has the right to appeal the line advance suspension once they have been notified?

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#2179026 - 05/21/18 08:44 PM Re: Unsecured Open End Credit - Suspended - Appeal I luv Giraffes
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
If this is just a typical line of credit, there is no appeal, unless your contract allows for one. You also did not answer my question.
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#2179495 - 05/23/18 09:27 PM Re: Unsecured Open End Credit - Suspended - Appeal I luv Giraffes
Andy_Z Offline
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I haven't worked a lot with lines of credit, but where does this suspension come from and why? I go back to Randy's comment on Reg B. If you've denied credit, that is not a suspension and I like to live in a black and white world, they do, or do not have a LOC and if they do they should be able to access it. Suspensions seems to be a way of providing a line without doing it and then having a liability if the borrower was harmed because of it.
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