Is Closing an Account Adverse Action?

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Question:

If we close a deposit account due to repeated overdrafts do we have to send an adverse action? No credit report was pulled to make the decision.

Answer:

If the account has an overdraft line of credit attached to it (credit), you are required to send an AAN under Reg B. If no credit feature is attached, your AAN is not required. It is only a customer service issue (then again, you probably don't care at this point). Since no credit report was used in this decision, the FCRA is not an issue.

First published on BankersOnline.com 3/19/07