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#1110567 - 01/14/09 03:06 PM Written notice content on reserve line restriction
Audit_Viking Offline
Member
Joined: Feb 2008
Posts: 73
MN
My bank is reviewing both HELOCs and unsecured (reserve) lines and making a determination if our borrower's creditworthiness (and for HELOCs only--the collateral value) has deteriorated to the point where we're looking to reduce/freeze these lines.

We're applying the FDIC's FIL 58-2008 recommendations of providing timely written notice (complete with reason) to borrowers on HELOCs.

What I'm wondering is does our unsecured line process also need to include this level of "tailored" notice, or can a more generic notice (i.e. "boilerplate") suffice for reserve line restriction actions we're taking?

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#1111205 - 01/14/09 10:48 PM Re: Written notice content on reserve line restriction Audit_Viking
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 85,241
Galveston, TX
What ever notice that you send, it will have to include the requisite requirements of an adverse action notice under Regulation B.
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