Most Popular Compliance Content
Send FCRA Adverse Notice to Individual & Company?
03/10/2008
We received a business loan application for ABC company. As part of the application the lender pulled a credit report on the primary owner of the company who agreed to personally guarantee the debt, but the credit was denied based on information contained in the credit report. Since the individual is not an applicant, does the FCRA adverse notice need to be sent to the individual as well as the company? I have had some interpret that notice does not need to be provided to guarantors, as technically they are not applicants and thus no adverse action is taken against them and some interpret that the notice needs to be sent to any individual for whom a credit report was pulled which contained the adverse information. Which is correct?
Business Debit Cards Linked to Personal Accounts
03/10/2008
We are starting a business debit card program. While working on our disclosures we have come across something we're not sure how to address: business customers who request to have personal accounts linked to their business debit cards. Is this a permissible practice, and what are some liabilities facing us in such a situation?
Lending DDA Funds
03/10/2008
Can banks lend DDA funds? I was under the impression that DDA accounts were not lended or invested.
Using CML LOC as Overdraft Protection
03/10/2008
Can a corporation or business use CML LOC as overdraft protection?
Five Reasons for Identity Verification in 2008
03/03/2008
What factors compel identity verification (ID verification) in 2008?