Does a Risk Based Pricing Notice and Credit Score Disclosure have to be provided with adverse action notice on denied deposit account?

No RBP notice and no separate Credit Score disclosure, but if you use a "credit score" as defined in the FCRA to decline the deposit account, then you would need to add the credit score information to the adverse action notice.

Thanks Ted

What about these companies that offer a "debit score"? Do you think that requires more in the way of adverse action? Or do you think the companies "Notice of Action Based on Information Contained in a Consumer Report" is sufficient? The notice gives all the information the customer needs to contact the company that gave the bank the information.

Thank you.

If you are basing your decision on a score and that score is statistically derived in some manner, you disclose the score and the range of scores and the reasons behind the score.

I believe they may be just calling it a 'debit score' to distinguish it from a 'credit score'. My opinion is that it will likely still fall under the definition of "credit score".