Our internal auditor states that we should be sending a Notice of Adverse Action for denied ATM and debit cards. Is this a requirement of the Fair Credit Reporting Act?
Our retail department wants to send debit cards out to customers that (1) currently just use an ATM card and (2) meet certain criteria. The department wants to "prescreen" by using the credit score of the customers with ATM cards only. No new product is technically being solicited, as the customer is merely receiving more access to their account. Would this violate the provisions of FCRA?
We have a customer who says that on Nov. 7, 2000, he called our bank to report his debit card lost. There had been $2750.00 charges on his card in one month. He said our bookkeeper at this time told him the whole loss was his. We have no record of his call. He stated in a letter to me April 5, 2002 that he knew he lost his card October 5, 2000 but just did not report it. Now he wants all but $500.00 back. Are we liable, since he knew a month earlier and did not report it, we could have stopped most of the charges? Also, after two years where do we stand with time limits? Also, some of these transactions were PINbased.
I was told that Reg B required us to send out an adverse action notice anytime we revoked a debit card. I'mconfused over this since Reg B deals with granting credit and a debit card accesses the checking account. Can you provide me some guidance?