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#27995 - 08/15/02 03:40 PM Reg. B Adverse Action-Renewals
Anonymous
Unregistered

If someone wants to renew a loan and we decide we can't, is that still considered adverse action? I think it is but I saw something in Reg. B. definition that said the term does not include a denial of an application for an increase. I know an increase is not a request for renewal but just wanted to see what someone thought. Thanks.

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Lending Compliance
#27996 - 08/15/02 04:26 PM Re: Reg. B Adverse Action-Renewals
Anonymous
Unregistered

Since you declined the borrwer's request to renew the loan, I definitely would consider it adverse action and send the appropriate notice.

Also, not sure where you read your difinitions, but a request to increase a loan that is declined would also consitute an adverse action.

My rule of thumb is that if we decline any type of loan request from a customer, we treat it as adverse action and send the appropriate notices.

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#27997 - 08/15/02 07:17 PM Re: Reg. B Adverse Action-Renewals
Anonymous
Unregistered

I agree what I was reading was referring to a point of sale and for refusal to authorize an increase in the amount of credit available. Thanks.

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