Why didn't my bank tell me why my credit card limit was lowered?

The situation

I live in Ohio and I am really frustrated with my bank right now. Last Tuesday, on October 15th, I logged into my mobile banking app to check my available credit, and I realized that my credit card limit had been slashed from $5,000 down to only $1,200 without any warning. I haven't missed any payments, and I've been a loyal customer for over four years. I called their customer service line yesterday, and the representative told me they couldn't give me a specific reason because the decision was based on some kind of automated report they pulled, but they wouldn't tell me which company provided the report or what my actual credit score was during the review. I tried asking for a written explanation or a copy of the info they used, but they just kept saying they couldn't help me over the phone. I want to know if they are required to send me a formal notice explaining this change, if they have to tell me exactly which credit bureau they used, and if I am entitled to see the specific score they used to make this decision. Do I have a right to a free report if they used a third party to deny my higher limit?

Detailed Analysis

Because your bank lowered your credit limit from $5,000 to $1,200 based on an automated report, this is considered an 'adverse action'—a legal term for a decision that negatively affects your access to credit. Under federal law, if a person takes an adverse action based on a consumer report, they must "provide oral, written, or electronic notice of the adverse action to the consumer"^[1]. This means they cannot simply change your limit without telling you.

Furthermore, the bank is required to give you specific details in that notice. They must provide a "numerical credit score... used by such person in taking any adverse action"^[1]. This means you are entitled to know the actual score they used to make the decision. They must also provide the "name, address, and telephone number of the consumer reporting agency" (the credit bureau) that gave them the report^[1].

Finally, the bank must tell you that you have the right to get a free copy of your report from that bureau. The law requires them to provide "notice of the consumer’s right—(A) to obtain... a free copy of a consumer report on the consumer from the consumer reporting agency referred to in paragraph (3)"^[1].

It is currently unclear if the bank's refusal to provide this information over the phone is a violation of the law or if they are simply waiting for the formal written notice to be mailed to you. However, the law requires the notice to be provided, and the representative's claim that they cannot provide the bureau's name or your score is contrary to these requirements.

Statutory Citations

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