But in this case, it seems like the credit union had no limit per person or for how many months. He did it month after month for $350,000 worth of CDs. A $300 sign up bonus per person is a hard limit (unless you are M&T). I get wanting to bring in money, but why wouldn’t they put a limit on it? Something simple like, “Free credit card funding on your FIRST CD up to $50,000.”
Guilty as charged. Was running 'em right up to, but never over, the limit. Then pay off just before statements close.
Agree this might not be smart. Things will change going forward. Hey, I’m learning here. 
While it’s hard to argue intent of a law, I will give it a shot anyway. Look at the official interpretation of the notification section:
Specifically, 9(b)(2) point 1.
- Number of specific reasons. A creditor must disclose the principal reasons for denying an application or taking other adverse action. The regulation does not mandate that a specific number of reasons be disclosed, but disclosure of more than four reasons is not likely to be helpful to the applicant.
Notice it mentions being ‘helpful’ to the applicant. This shows that the intent of the law is to help consumers understand credit decisions, not to prove that the adverse action was legal in itself.
Well, yeah. And it also use to be much easier to get a promo from a bank, then get another promo, then another (I once had over 10 BofA accounts, opened month after month, each earning a $100 bonus). Banks learn. This credit union apparently chose to filter out the abuser, while others tweak what’s allowed if not pull the credit card funding option altogether. They all react differently; the one similar factor is that they all go into it without anticipating how it might go sideways.
Sure, I agree that there are lots of arguments for intent of the law and most lawyers would have no trouble arguing many different “intents” of a statute or provision. The regulations do actually state the purpose of the statute at 1002.1. Much of the rest of the statute also discusses primarily discrimination based on classes.
While the CFPB’s interpretation of its own regulation may hold some weight, I would argue you are placing too much emphasis on a single word in an interpretation of the regulation (not the regulation itself). Even if it did hold significant weight, I think you are drawing an incorrect conclusion of what “helpful to the applicant” means, and it would be more harmonizing with the rest of the statute and regulations to define it as helpful to the applicant in knowing whether they were discriminated against, not in understanding credit decisions. No part of the rest of the statute is about understanding credit decisions.
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I’m hardly the only person that interprets this section that way.
Adverse action notices under the ECOA and Regulation B are designed to help consumers and businesses by providing transparency to the credit underwriting process and protecting against potential credit discrimination by requiring creditors to explain the reasons adverse action was taken.
Thanks for sharing! This was very informative.
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I disagree with your interpretation of the passage you quoted. But to be clear, I am not saying that there is no colorable claim. I am also not saying that you have to allege discrimination in order to prevail. I’m just saying that saying one is likely to prevail seems like a stretch. I’m also saying that the purpose of the notice requirement is not to educate consumers on underwriting procedures/standards. You could argue that it’s designed to allow people to correct incorrect information that the lender/creditor has, but that’s still not about educating consumers.
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^^^ This is an interesting and valuable discussion that IMO deserves its own thread, if either of you are willing to start or post your next response in a new thread…
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Regardless of the intent of the law, an arbitrator would not find your filing frivolous. Arbitration is rather expensive for the card issuer, so they would likely want to settle prior to that. I cannot cite specific examples.
This is merely a heads up. In light of recent events I have, as you might imagine, been watching credit reporting on myself rather closely. Only this morning, for the first time after nearly three weeks following the fireworks, was I able to gain access to the second of the services upon which I rely for that reporting. I picked up a subtlety I want to report to you. It’s likely nothing. I’m going to report it anyway, just for your information:
Looking at my credit card accounts which no longer are operative, of which three more sadly now exist than prior, I focused on the reason given by the credit report for each account’s demise. Then I compared with language used in the report regarding other accounts which I had closed on my own.
Credit card accounts which I closed, which were closed at my request, were listed as having been “closed”. Accounts terminated for cause by my credit grantors were listed as “cancelled”.
It’s a subtle difference, obviously. But it is more than sufficient for those skilled in the art of credit analysis, or for a computer programmed to pick up on such differences, to be placed on notice and send up a red flag.
This is pursuant to the PayPal CC rewards transfer delay mentioned up thread. Almost exactly 24 hours after receiving the above-posted delay notice, I just received this email communication from PayPal:
We’re transferring money to your bank
You asked us to transfer $250.00 USD to your bank account, and we’re processing this transaction now.
Estimated arrival: 1 business day
Transfers made after 7:00 PM ET or on weekends or holidays take longer. All transfers are subject to review and could be delayed or stopped if we identify an issue.
I now believe this delay was merely a coincidence, something unrelated to other recent events documented on this thread. I write that even though this happened for the very first time after numerous previous uneventful transfers of funds to my bank.
After research, apparently PayPal pulls this stunt frequently. Consider a large proportion of their business is generated as an outcome of eBay transactions. And eBay activity can be problematic for any number of reasons, all far off topic here. So you can forgive PayPal in those instances.
But the funds in question here landed in my PayPal account NOT as result of anything happening on eBay. There is no connection to eBay whatsoever. My funds came straight from Synchrony Bank. They are rewards payout funds and carry no eBay taint at all.
Many complainants on the net claim PayPal delays transfers, and holds onto funds, solely to collect interest on the money they fail timely to transfer. Based on my experience, I agree.
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It’s meaningless. You will see zero effect from that subtlety, it raises no red flags.
There really isnt any such thing as “terminated for cause” on a credit report. Their “cause” is that they chose to no longer do business with you; regardless of the reason they state, it’s still completely subjective on their part. No bank is going to let their lending qualifications be influenced by another bank’s whim.
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@shinobi, here’s an anecdote for you. Today I got an email from Huntington Bank regarding my Voice Mastercard with them. They lowered my credit line from $10K to $8,300. This doesn’t affect my life in the slightest. I have never, ever had one of my credit lines lowered though. I can only guess that it’s because we took out a car loan for a new car purchase last Saturday. We also have a car loan outstanding from a new car purchase in 2017. Normally, such big ticket purchases are more staggered, but our son just got his driver’s license and we gave him the oldest car for his own.
Funny! We’re using FWF methodology of borrowing when rates are lower than my current investment yields. We could have paid cash for both cars without breaking a sweat and can pay off the loans today, if we wanted to. And they think I’m a credit risk? 
Agreed. They too often have no real clue who is a credit risk and who is not. So they play safe leaving many of us victims of their discernment shortfall.
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I’m not a bank apologist, but to be a little fair to them, when they didn’t play it safe, we all know what happened.
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There’s a good chance that the two auto loans are not related to your CL cut at Huntington. Auto loans are collateralized, and as such fit into a different FICO compartment. Often, scores go up when a new auto or mortgage loan is opened.
Used the card very lightly or not at all?
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Thanks for the info. I use it every month, about $300 to $600 worth, paid in full every month, without fail. I have several other credit cards, some of which get used more regularly than others, depending on quarterly bonuses at the time. Some credit cards may not get used for several months, but none have ever lowered my credit line. Oddly, some of the least used cards have increased my credit line at times.
Huntington is a bit of an oddball in that I had to apply for this card in person, because I wasn’t already a bank customer. Maybe they’re an oddball in other ways?
The paperwork at the car dealership shows our credit scores to be 841 and 842. My husband makes low 6 figures, which Huntington knows. No mortgage. We paid cash for our house in 1996. Our only debt of any significance, IMO, is the car loans.
I just called Huntington to see if I could get an exact reason. They sent out a letter that is supposed to give that. The rep said that their credit department changed criteria for getting credit, and many people had their credit lines lowered because of the new criteria. It might be just that, or the new car loan increased the debt to income ratio too much, in their opinion.
Yet, they don’t provide any means for updating income, as some other card issuers do. The only time they’ll update that information is when someone requests a credit line increase, which I’m not able to do now for 6 months. I’ve never requested one and would not do so just to get them to update their records.
Do you want me to post back when I find out the reason?
Sure, post back. I doubt it will be very informing though… I will likely be a simple form letter with not very specific information as to why the cut in CL.
So, with your scores, income, lack of other debt, you are in an elite group and I’ll stand by what I said earlier about it not being about the car loans (adding) UNLESS Huntington is really wonky about such things.
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Especially if I don’t ever get that letter. Sigh.