I have an unusual situation. I have a customer with two paid, closed loan accounts at my bank. This customer has several 30+ lates on these accounts. He disputed them earlier this year (yes, they were both closed and paid at this time) and our bank 'verified' the disputes. He has since sent the bank a letter asking if we ever actually received those dispute forms from the CRA's. We went to our archived records and found that we in fact, did receive one dispute form, but we have no record of the other (only tu and eq involved). We decided to do a manual audit of the complete history of the accounts, and in doing so, we pulled all three of his CR's. He is now threatening to sue the bank for pulling w/o permissible purpose, citing a FTC opinion letter that addresses this issue.
We believe we are allowed to pull for purpose of account review.
My question to you guys is this---Are we wrong? He is contending that since the accounts are paid and closed, that we have no right to pull w/o his permission.
We are at a loss, and our legal staff has mixed opinions concerning this.
Any thoughts???