Question: Our consumer lending center sometimes takes calls from consumers who want to apply for a mortgage loan.
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?
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?
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?