Question: We sometimes obtain a credit report and a credit score on a consumer before opening a deposit account with an overdraft line of credit. Does this trigger the FACT Act credit score notice? We are making a credit decision.
Answer: Although you are making a credit decision, you are not making the type of credit that would trigger the credit score notice. That notice is limited to consumer loans that will be secured by 1-4 family residential real property. Overdraft lines of credit are not included in this notice requirement. So you do not have to give those deposit account customers a credit score notice.
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