TOPIC: Adverse Action

Adverse Action - IDology

Person at a bank ($27.1BUSA)
We started using IDology for KYC on new account applicants. Unlike Qualifile or credit bureau, IDology looks at public data and presents KYC questions. If a client fails their KYC questions we send an adverse action notice. The question was what to put on our Adverse Action notices. IDology uses public data from LexisNexis, and they provided us a public LexisNexis website & address for someone to dispute their public data. Our compliance folks don't think we can just stick LexisNexis contact info on the adverse action notice, even though that's what IDology provided that their other banks are doing. Does anyone out there use IDology?

    HELOC Termination

    Director at a Company (USA)
         We just received an insurance check for HELOC on our books that would pay off the loan.  This borrower hasn't carried insurance on the property and we have had to force place for quite some time. The Loan Department would like to pay off the loan with the insurance check that was received and terminate the HELOC.  What else would we need to do besides provide a notice of adverse action?

         Originally posted by an anonymous author with the title AVP Regulatory Compliance and Legal on 15 Jul 2019 to CBANC FI Professionals Community.


      Manager at a credit_union ($97MUSA)

      Hello! I am wondering how everyone else handles old/expired indirect applications. We are trying to keep our lending queues within our LOS clean and up to date with current applications, making sure that once the application has expired that we are sending out an adverse action to let the member know that he/she would need to reapply as the credit has expired. We started doing this on the indirect side last month, by declining them within our system it alerted the dealerships of new activity through Dealer track/Route One and they are less than thrilled about all the RED marks showing on their side. What do you guys do to remove the expired applications? Do you send out an Adverse Action? Do you let it age out of the system? Do you just “cancel” it, and make it go away? Any incite on this is appreciated!

        Monitoring tool Updated - Adverse Action Checklist

        VP at a bank ($903MUSA)

        I have revised a tool I may have provided a long time ago - it is designed to use as you go through an adverse action file, with one section focused just on the notice itself. Now includes MLA and better flow (IMHO). Might need a little tweaking for your bank's process. Hope you find this helpful - I also use this to train others on what to look for in the file for compliance purposes.

          Restricting or Terminating a Overdraft Protection account

          COO at a bank ($293MUSA)

          Would someone be willing to share the form or notification they use to notify a customer they are restricting their Overdraft Protection account?

          Would you also be willing to share under what events you might terminate or restrict a plan (borrower moved out of market area, no deposit to account tied to the ODP in 'xx' number of days, etc.)?

          Thank you.