I need a little guidance. Initially I was thinking the answer to both is no because an AAN was either not required or already provided, but then again this seems like it is a new refusal to extend credit in both cases.

1. If a credit card account is closed by the bank due to inactivity, default, or delinquency and no AAN was provided (because one is not required) and the consumer calls to request the account be re-opened would an AAN be required for the denied re-open request?

2. If a credit card account is closed by the bank and an AAN is provided and the consumer calls to request the account be re-opened would an AAN be required for the denied re-open request?

I think you're missing a step in the process. If an account is closed, then that account exists no more. Discussion with the former account-holder should take the form of an new application--following your established procedures for taking applications from consumers, in general. If the new application is not approved, then the usual AAN would be issued.

So, if we simply provide to the consumer that we will not re-open their account and no further actions are taken that would equate to receipt of an application, according to policy, then an AAN would not be required?

(f) Application means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested. . . . . . .

2. Procedures used. The term “procedures” refers to the actual practices followed by a creditor for making credit decisions as well as its stated application procedures. For example, if a creditor's stated policy is to require all applications to be in writing on the creditor's application form, but the creditor also makes credit decisions based on oral requests, the creditor's procedures are to accept both oral and written applications.

So, if you close my account and I make an oral request for you to reopen the account (grant me additional credit) and you make an adverse decision not to grant me new credit you have taken adverse action on an oral application.

Section 1002.2(c)(ii) of Reg. B defines "adverse action" to EXCLUDE "Any action or forbearance relating to an account taken in connection with inactivity, default, or delinquency as to that account." Your original post says that account is "closed." If the former cardholder wants to talk about your reasons for closing that account, then the definition tells you that whatever you say or do is NOT adverse action and therefore no AAN would be triggered. Recognizing that the old account is closed, any further discussion about credit card service means you are now talking about a new extension of credit. The cleanest way to proceed is to require the customer to submit a new application--which you will process, approve, or deny in the same manner you would handle a credit card application from me.

Thank you both! This has helped me tremendously.