I believe the keys to this are in the definition of adverse action. And if you take adverse action, when a notice is needed.
(c) Adverse action. (1) The term means:
(ii) A termination of an account or an unfavorable change in the terms of an account that does not affect all or a substantial portion of a class of the creditor’s accounts;
So this tells you canceling an account is adverse action. But-
(2) The term does not include: (ii) Any action or forbearance relating to an account taken in connection with inactivity, default, or delinquency as to that account;
tells you that canceling the account under some circumstances is not adverse action.
Termination because of a problem on another account with you or someone else is one thing, but a payment problem on this account is another.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell