Credit Report Use
by Lucy Griffin, BOL Guru
Guru Bios
Question: If we have obtained a full credit report on a consumer for purposes of opening a transaction account, can we use the credit report for other purposes, such as determining whether to market credit products to that customer?
Answer: You must have a legitimate business purpose for obtaining the report in the first place. This purpose is met by your consideration of the consumer's request to open an account. Once you have the report, you may use it for other appropriate purposes, such as marketing a credit product offered by the bank, but the report should stay within the organization that requested it. Affiliate sharing of this information may only occur after you have given the customer an opportunity to opt out. The FACT Act will make this notification requirement more specific.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 8, 8/04
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