Question: Our consumer lending center sometimes takes calls from consumers who want to apply for a mortgage loan.
Which section of the Fair Credit Reporting Act regulates the issue that a customer's credit report should be obtained only after consumer authorization?
The Federal Reserve Board recently issued a final regulation regarding section 217 of the FACT Act. It provides models that servicers can use to notify borrowers that negative or derogatory information has been provided to a nationwide credit bureau. The final regulation indicates an effective date of July 16, 2004. Everything else we have read has a notification compliance date of December 4, 2004. Which date is correct?
We have recently started issuing debit cards and are not sure which "notice of action taken" should be used when a customer is declined a card. We have different types for loans and deposit products. Which should we use?
Add "V" to Your Regulatory Alphabet
by Mary Beth Guard
When a customer is denied a debit card, what kind of disclosure must they receive? At previous banks we used a form similar to an adverse action for loans, but it didn't have as much info on it. Where can I find this info in the regs?
<a href="http://www.bankersonline.com/articles/v05n14/v05n14a2.html">There is an article by Lucy Griffin on FCRA, ECOA, and Adverse Action Notices.</a>. In talking to the FDIC, who referred me to the FRB issuance dated March 2003, Reg B now states that we do not need to send a separate adverse action notice to the co-applicant if his/her consumer credit report was used to deny a joint credit application. The FRB states that when a person agrees to be a co-applicant, there is a general understanding that information will be shared between the applicants. Therefore, we do not need to inform the primary applicant that there is an "ineligible co-applicant" and send a separate notice. The FDIC is asking me to find out what information you are referring to in the above article by Lucy Griffin.
A new customer opens a checking account. You give him an ATM card, which he wants, but he also requests a debit card. When you run a credit report and his credit does not warrant a debit card, do you have to give him a written adverse action notice?