I have done some searching through past postings and learned that when Chex Systems is used to deny ODP during the initial account opening that a FCRA AAN is required.

That being said, how about when the customer has had the account open for six months with ODP, and because of his abuse of the ODP program, the bank now wishes to either eliminate his ODP priveledge or close the account entirely, is an AAN required under Regulation B?

As long as your ODP program falls under the definition of "incidental credit", a Reg B adverse action notice would not be required.

Rick,

Do you know where I might find the definition of "incidental credit"?

Randy, you really need to stop "posing" as "Rick"! Or is that your "assumed name," and, if so, is it registered with the state?

Oh, Clint had a question. The definition of "incidental credit" can be found in Regulation B, section 202.3(c).

My apologies to Randy.

I can't find my horse either!!!

My thanks to John. (He's got his full name upfront, so I have no excuse)

Thanks again to both of you. Your expertise is much appreciated. See you in Vegas!!!

Oh - I've been called worse things than Rick or Richard