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Old 11-15-2008, 05:00 AM   #37
statman
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Join Date: Jan 2006
Location: Lehi, UT - God's country. (County?)
Posts: 27
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I just read-up on it a bit & i remember what our lawyers used to quote us - First: (from 202.2)

Definition of adverse action: "(ii) A termination of an account or an unfavorable change in the terms of an account that does not affect all or substantially all of a class of the creditor’s accounts; "

In other words, if it DOES affect all or substantially all of my accounts - like an across-the-board reduction in unutilized credit line - and I don't use credit information in making that decision, it's not an adverse action situation and I don't need to notify the customer of anything.

The stated reasons for notifcation - as specified in Reg B - is to keep consumers informed and up-to-date about their credit information & how it is being used. If I make a lending/exposure/policy decision that is applied across the board and doesn't use credit information, I have no need to inform them. It has nothing to do with their credit...
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