Balloon Matured-Chose not to renew-Denial Notice?

Our bank loaned money to a borrower secured by a home owned by the borrower and his brothers (used as rental property)with a 5 year balloon. Borrower signed note, borrower and brothers signed the DOT. The loan was for closing costs and down payment on borrower's purchase of a primary residence. Primary residence was foreclosed on after 2 1/2 years. The balloon note matured last month. Borrower called yesterday and asked what needed to be done and was told that the bank will not be renewing the note. Does a denial notice need to be mailed? No new application was taken but is borrower's request for the loan to be renewed considered an application?

I need to make sure file is well documented due to the borrower's statement that he will be filing a complaint against the bank for discrimination based on he is now mentally disabled. His disability has nothing to do with the bank's decision not to renew. The decision is due to the foreclosure and poor credit performance with the bank.

Thank you in advance for your assistance.

Yes, his request is enough to trigger the need for an adverse action under Reg B. He asked, the bank said no.

Exactly what I thought. Thank you, Kathleen.