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#2282227 - 03/14/23 06:58 PM Decline-Internal Policy Limits Credit to 20%
Likes to Comply Offline
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Joined: Nov 2008
Posts: 1,074
In the mountains
Our internal policy is to limit a credit card limit to 20% of an applicant's annual salary/income. So we may have to issue a combined counteroffer/decline offering a lower credit limit when what is requested is more than that amount.

We realize that statements that adverse action was based on internal standards or policies are not sufficient under Regulation B and to say that income is insufficient for the amount of credit requested seems to leave applicants with questions because maybe their income is enough for a higher limit than what we have limited it to for our own internal purposes.

I am looking for suggestions on what to say as the decline reason that will be clear/adequate but would not fall into that "statement that adverse action was based on internal policies" arena.

Maybe - Income in relation to revolving credit line requested is insufficient - ?

Suggestions would be appreciated!
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Lending Compliance
#2282230 - 03/14/23 07:54 PM Re: Decline-Internal Policy Limits Credit to 20% Likes to Comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 81,304
Galveston, TX
Insufficient Income or I guess "Income in relation to revolving credit line requested is insufficient", Either one would work.


Paragraph 9(b)(2).
3. Description of reasons. A creditor need not describe how or why a factor adversely affected an applicant. For example, the notice may say “length of residence” rather than “too short a period of residence.”
Last edited by rlcarey; 03/14/23 08:01 PM. Reason: Redid my answer after a second reading
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