Is the adverse action notice required on a suspension letter sent to borrowers due to fraud? ECOA requirements state that adverse action does not include "a change in the terms of an account expressly agreed to by an application." If the Note indicates that the account will be suspended if fraud is noted, then would this notice not be required?

Thank you!

What type of fraud are you talking about?

Fraud that has come about based on origination documents (altered documents later noted).

Then it is a trigger for default and action taken based on default is not adverse action.

Thank you!

And do not forget your SAR

Yes, covered! Thank you.