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#1762013 - 11/28/12 11:25 PM Notice of Negative Info - deposit
Lele Offline
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Lele
Joined: Feb 2007
Posts: 827
In the Sun
Is this notice sufficient for FCRA notice to consumer purposes?
"Credit verification. You authorize us to request and obtain one or more credit reports about you from one or more credit reporting agency for the purpose of considering your application for the account, reviewing or collecting any account opened for you, or for any other legitimate business purpose. You authorize us to disclose information about your account to a credit reporting agency if your account was closed because you have abused it."
Thanks!!
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#1762015 - 11/28/12 11:32 PM Re: Notice of Negative Info - deposit Lele
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,350
Galveston, TX
You are not extending credit when you open a deposit account:

(7) Negative Information

(A) Notice to Consumer Required

(i) In general. If any financial institution that extends credit and regularly and in the ordinary course of business furnishes information to a consumer reporting agency described in section 603(p) furnishes negative information to such an agency regarding credit extended to a customer, the financial institution shall provide a notice of such furnishing of negative information, in writing, to the customer.

There is no requirement to give them notice that you are going to pull a credit report.
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#1762045 - 11/29/12 02:57 AM Re: Notice of Negative Info - deposit Lele
Lele Offline
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Lele
Joined: Feb 2007
Posts: 827
In the Sun
OK. This is the verbiage that was used when we changed to a new deposit platform and they said this is compliant for the notice. I disagreed but wanted another opinion.
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#1762358 - 11/29/12 06:08 PM Re: Notice of Negative Info - deposit Lele
Lele Offline
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Lele
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Posts: 827
In the Sun
@ RLCarey - just trying to clarify, though this was included in out deposit account opening disclosures, it was not required because we are not extending credit?
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#1762362 - 11/29/12 06:11 PM Re: Notice of Negative Info - deposit Lele
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,350
Galveston, TX
I don't believe so. Do you report overdrawn checking accounts to one of the big three credit reporting agencies? You also have to be reporting to a Nationwide CRA to trigger the notice negative requirement.
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#1762389 - 11/29/12 06:24 PM Re: Notice of Negative Info - deposit Lele
Lele Offline
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Lele
Joined: Feb 2007
Posts: 827
In the Sun
We only report NSF/Chargeoffs to ChexSystems. Do we have to notify the customer that we are doing that? Thanks...
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#1762426 - 11/29/12 07:22 PM Re: Notice of Negative Info - deposit Lele
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,350
Galveston, TX
Nope.
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