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#870321 - 12/11/07 03:13 PM Commercial Renewals and Adverse Action
tickledpink Offline
Junior Member
Joined: Feb 2006
Posts: 37
Currently we provide a "adverse action" letter on lines of credits we are not renewing. Does all the same content apply to those letters as stated in Reg. B as in the case of a new application? The banks name and address must be on the letter, specific reasons, etc.?

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Lending Compliance
#870355 - 12/11/07 03:41 PM Re: Commercial Renewals and Adverse Action tickledpink
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,464
Bloomington, IN
If you are terminating these LOCs due to delinquency or default on the account you do not need to send an AAN. See the definition of adverse action at 202.2(c).

However, if you are denying a request to renew the LOCs then the AAN requirements of 202.9 apply. They would also apply if you are reviewing the LOCs for renewal and are denying the renewal based on some other adverse reason.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#870383 - 12/11/07 04:00 PM Re: Commercial Renewals and Adverse Action Dan Persfull
tickledpink Offline
Junior Member
Joined: Feb 2006
Posts: 37
Yes, we are reviewing the LOCs for renewal.

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