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#2157258 - 12/14/17 03:38 PM Denying a loan app from a current abusive customer
BSAguy Offline
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Joined: Aug 2007
Posts: 278
Kansas
We have a customer who has 3 loans with us. The first one is by himself. The other two are joint with his girlfriend. They both have good credit. Since these have been made, only the girlfriend has come into the bank. The problem is that she is verbally abusive to our employees. She also appears to be very manipulative. She has somehow also gotten local churches to make the payment on their mortgage loan in recent months. She receives disability when it doesn't appear that she's disabled. The bottom line is she's just an all around foul person that none of our employees want to deal with.

The last time she was in the bank she said that she wants to apply for a car loan once she gets her tax return money in late January or early February. We really don't want anything to do with her. I've read another post where someone recommended getting a restraining order. With them already having loans with our bank, I don't see that as an option in our situation. I'm thinking we just let her apply then send her a denial. Does that sound like a reasonable plan? How would you word the denial reason?

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#2157317 - 12/14/17 06:29 PM Re: Denying a loan app from a current abusive customer BSAguy
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,007
Toano, VA
This has the potential to get ugly and waste more than a little of your time. Because you know this person is abusive and manipulative and you're preparing to butt heads over a credit application (and possibly the handling of existing credits), now's a good time for a Reg. B review. You don't want to stumble into an unexpected Reg. B issue that could compromise your position.

Start with the protected characteristics and walk through the rules for taking applications, making credit decisions, and providing notifications.

One of those protected characteristics you never think about is good faith exercise of any right under the Consumer Credit Protection Act. The classic "exercise of rights" training example deals with cancellation or restriction of a credit card (or other revolving consumer credit) because the customer has been a nuisance -- including frequent use/abuse of the billing error resolution right. Because billing error resolution is a CCPA right, what you might consider adverse action becomes illegal discrimination.

That particular right isn't relevant to your upcoming confrontation, but the CCPA establishes many types of consumer protection. Now's a good time to take a close look at all of the assorted CCPA rights and think what might be thrown at you by this problem customer.
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#2157338 - 12/14/17 08:10 PM Re: Denying a loan app from a current abusive customer BSAguy
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
This is a sticky situation because she sounds like the kind of person that may do everything she can to make your life hard if she believes you are on her "nasty list". However, you don't have to make a loan to rude or abusive people. That's not a protected class.
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#2157385 - 12/15/17 11:46 AM Re: Denying a loan app from a current abusive customer BSAguy
Rocky P Offline
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Joined: Jun 2003
Posts: 7,258
Florida
Make sure that the bank fully documents each and every time that she has become abusive to staff. That will make your response to the regulators inquiry a lot easier.
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#2237772 - 06/09/20 06:22 PM Re: Denying a loan app from a current abusive customer BSAguy
Snowgirl Offline
Platinum Poster
Joined: Sep 2003
Posts: 709
What about when you have a consumer who does not have any loans with us, but has been verbally abusive to our staff on the deposit side and now wants to get a loan? What is the reason for denying? Can you state prior bank experience even though it was not on the loan side?

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#2237776 - 06/09/20 06:47 PM Re: Denying a loan app from a current abusive customer BSAguy
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,568
Galveston, TX
Sure you can. You can tell them it is because they always wear a blue shirt if you want to, as long as it is not based on a prohibited basis.
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#2237783 - 06/09/20 07:47 PM Re: Denying a loan app from a current abusive customer BSAguy
TryingtoComply Online
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Joined: Apr 2013
Posts: 1,827
The West
I would consider closing the deposit account. Why let this customer treat your staff badly?
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