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#1637483 - 12/09/11 05:19 PM Is this correct?
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We pull credit reports for new account (deposit, savings) applications/requests. If denied, would we only owe the customer the FCRA portion (Discolsure of Use of Information Obtained from an Outside Source) of the AAN? Do we owe the applicant a reason?

Also, if the request is for joint-owners would we only need to provide the notice to the persons whose credit report was the reason for the denial?
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#1637495 - 12/09/11 05:30 PM Re: Is this correct? Likes to Comply
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Does the FCRA portion of the AAN apply to businesses? If a business applies for a new account, we pull a credit report on the owners of the business. So if the account application is denied, should we give the owners an AAN?
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#1637502 - 12/09/11 05:38 PM Re: Is this correct? Likes to Comply
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Do we owe the applicant a reason?

Only on applications for credit.

Also, if the request is for joint-owners would we only need to provide the notice to the persons whose credit report was the reason for the denial?

Correct.

Does the FCRA portion of the AAN apply to businesses? If a business applies for a new account, we pull a credit report on the owners of the business. So if the account application is denied, should we give the owners an AAN?

Unless they are going to be personally liable for the account as an individual, then you need written authorization to pull a report. If they are not an applicant (i.e. guarantor), they would not recieve the FCRA AAN.
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#1637553 - 12/09/11 06:28 PM Re: Is this correct? rlcarey
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Thanks for the help!
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#1637588 - 12/09/11 07:06 PM Re: Is this correct? Likes to Comply
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One more question...would this be the same for debit card applications? Does it make any difference if the account had an overdraft privilege program attached?
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#1637595 - 12/09/11 07:09 PM Re: Is this correct? Likes to Comply
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would this be the same for debit card applications?

Yes

Does it make any difference if the account had an overdraft privilege program attached?

No
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