You should re-read the new 226.5 effective Aug. 20th. Credit Card financial do not need to give notice of account closure and BOA did under the rules include an entire class of creditor's, most of their good customers who had higher credit limits with low to no balances & those with higher balances and only making min. installment payment. Albeit BOA motives were both to reduce perceived credit risk and as a knee jerk reaction to the CCARDA laws. A new wave of fee based credit cards will begin to appear soon costing consumers even more for open-end credit tied to plastic.
There are no winners here, thank you congress!
I can't find in 226.5 where it says this. Can you point to the part that calls this out? Also, this doesn't appear to be consistent with the definition of adverse action in 202.2(c)(1)(ii), so why again is a notice not required? The exclusion applies to actions that impact all or substantially all of a class of the creditor's accounts. Your example is that "most" accounts that meet certain criteria around paydown rates (one example). Not eveyone has a high line or a high line with low paydown. I read this as different than "all or substantially all", particularly when compared to current practices of cancelling all accounts that have a bankruptcy filing notice - everyone with a notice is cancelled, but each person also receives an adverse action notice with reasons.
Not trying to argue, just trying to more clearly understanding the reasoning.
|
