Skip to content
BOL Conferences
Thread Options
#976936 - 06/18/08 11:59 AM Change in Terms & Adverse Action
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 530
Midwest
Is there any guidance on how to define "class" as mentioned in the definition of Adverse Action under Reg B? The question revolves around a change in terms we are doing, and whether the changes affect all or substantially all "of a class of creditor's accounts".

Return to Top
Lending Compliance
#977130 - 06/18/08 02:34 PM Re: Change in Terms & Adverse Action M&M
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
If you are raising the interest rate on all accounts within a specific account type, that would be a class of accounts. If you are individually selecting accounts to raise the interest rate on, then that would not be considered a class of account.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z