Unless your loan agreement creates a renewal notice obligation, we are not aware of any requirement to notify a borrower of your intent to not renew a loan, either before or after the loan’s maturity.

However, we do note that Regulation B requires a lender to send an adverse action notice within 30 days after receiving a completed application for an extension of credit. Under the rule, an “extension of credit” includes a “renewal of credit.” Consequently, if the borrower requests a loan renewal — either orally or in writing — you must notify them of your decision to deny their renewal within 30 days of receiving their completed application.

For resources related to our guidance, please see:

• Regulation B, 12 CR 1002.9(a)(1) (“A creditor shall notify an applicant of action taken within: 30 days after receiving a completed application concerning the creditor's approval of, counteroffer to, or adverse action on the application…”)

• Regulation B, 12 CFR 1002.2(f) (“Application means an oral or written request for an extension of credit . . . .”)

• Regulation B, 12 CFR 1002.2(q) (“Extend credit and extension of credit mean the granting of credit in any form (including, but not limited to . . . the refinancing or other renewal of credit . . . .).”)

• Regulation B, 12 CFR 1002.2(f) (“. . . A completed application means an application in connection with which a creditor has received all the information that the creditor regularly obtains and considers in evaluating applications for the amount and type of credit requested (including, but not limited to, credit reports, any additional information requested from the applicant, and any approvals or reports by governmental agencies or other persons that are necessary to guarantee, insure, or provide security for the credit or collateral). The creditor shall exercise reasonable diligence in obtaining such information.”)